ML19263E215

Forwards OL Change Request 71,adding Info to SER for Fire Protection Program.W/Supporting Documentation

ML19263E215
Person / Time
Site:	Oyster Creek
Issue date:	06/01/1979
From:	Finfrock I JERSEY CENTRAL POWER & LIGHT CO.
To:	Office of Nuclear Reactor Regulation
References
TASK-09-06, TASK-9-6, TASK-RR NUDOCS 7906050319
Download: ML19263E215 (14)

Text

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Jersey Central Power & Ught Company Madison Avenue at Punch Bowl Road f Momstown, New Jersey 07960 (201)455-8200 June 1, 1979 Director Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 License Change Request No. 71 By letter dated March 114, 1979, we requested a schedule change for certain fire protection modifications. In subsequent conversations with your staff, it was requested that we submit a License Change Request in order to allow for' appropriate review and approval.

Enclosed is the requested License Change. Attachment.1 presents a requested change to Table 3.1 of the NRC Fire Protection Safety Evaluation Report. Attachment 2 presents a discussion of currently planned changes to our program and of the safety significance of the requested change in schedule.

This License Change Request has been reviewed and approved by the Station Superintendent, the Plant Operations Revi'w Committee, and an Independent Safety Review Group in accordance with Section 6 of the Oyster Creek Technical Specifications.

The enclosed submittal has been evaluated and classified in accordance with 10CFR170.22. The change to paragraph 3.E of the Operating License is deemed Pro Forma in nature and therefore is a Class II Amendment. As per 10CFR170.22 enclosed is a check for $1,200.00.

Very truly yours, af Ivan R. Finf k, r.

Vice President la 2294 024 7906050 3 / / f v

Jersey Central Power & Light Company is a Member of the General Public Ut& ties System

JERSEY CENTRAL POWER & LIGHT C0iPAl."I OYSTER CREEK NUCLEAR GEllERATI!!G STATION Provisional Operating License No. DPR-16 Operating License

. Change Request !!o. 71 Docket No. 50-219 Applicant submits, by this Operating License Change Request l'o. 71 to the Oyster Creek Nuclear Generating Station Operating License, changes to incorporate supplemental infonnation to the NRC Safety Evaluation Report on the Oyster Creek Nuclear Gcnerating Station's Fire Protection Program.

JERSEY CENTRAL POWER & LIGHT COMPANY BY gyj ,o VICE PRESI ..NT STATE OF !!EW JERSEY )

)

COUNTY OF MORRIS )

Sworn and subscribed to before me this / day of p#, 1979

,a _ . ~ A -

Notary Public M AIfCN 1A. pr'EESE NOTAR Y TUil!C CF NIW j!p sEY M r Gdt m6.n En ;res Mrt. 27,1,'al 2294 .25

UNITED STATES OF AMERICA liUCLEAR REGULATORY C0K4ISSION IN 'IliE 14ATTER OF ) ,

) DOCKET No. 50-219 JERSEY CENTRAL POWER & LIGHT CaiPANY )

CERTIFICATE OF SERVICE This is to certify that a copy of Operating License Change Request No. 71 for the Oyster Creek Nuclear Generating Station Operating License, filed with the U. S. Nuclear Regulatory Cornission on June 1, 1979 has this ISt day of June 1979 been served on the Mayor of Lacey Township, Ocean County, tiew J,ersey by deposit in the United States Mail, addressed as follows:

Be lionorable Mary Lou Smith Mayor of Lacey Township P. O. Box 475 Forked River, liew Jersey 08731 JERSEY CEl' TRAL POWER & LIGHT CQ4PANY BY d4/

Vice Presid t DATED: June 1, 1979 2294 ;26 I

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3. . , Jersey Central Power & Light Company W [ Madison Avenue at Punch Bowl Road M>

-%4' kd .-lff h Mornstown, New Jersey 07960 (20?)455-8200

- June 1, 1979 The lionorable Mary Lou Smith Maypr of Lacey Township P. O. Box 475 Forked River, New Jersey 08731

Dear Mayor Smith:

Enclosed herewith is one copy of License Change Request No. 71 for the Oyster Creek Nuclear Generating Station Operating License.

This document was filed with the U. S. Nuclear Regulatory Commission on June 1,1979.

Very truly yours, AN 1 Ivan R. Fin ock Jr.

Vice Presi ent la Enclosure 2294 27 f

Jersey Centra' Power & Lg;ht Company t, a Membe of the Generai Pubhc Utihties System

Oyster Creek Nuclear Generating Station Provisional Operating License DPR-16 (Docket !b. 50-219)

Applicant hereby requests the Ccmnission to change Provisional Operating Licensing DPR-16 as follows:

1. Sections to be changed:

Paragraph 3.E of the License.

2. Extent of changes:

Addition of SER supplements.

3 Changes Requested ,

Change paragraph 3.E of the license to read as follows: (Changes Underlined)

E. The licensee may proceed with and is required to ecxnplete the modifications identified in paragraphs 3.1.1 through 3.1.23 of the NRC's Fire Protection Safety Evaluation (SE),and supplements thereto, on the facility dated March 3,1978. 'Ihese modifications shall be completed as specified in Table 31 of the SE,and supplements thereto. In addition, the licensee shall submit the additional infor nation identified in Table 3 2 of the SE in accordance with the schedule contained therein. In the event these dates cannot be met, the licensee shall submit a report, explaining the circunstances, together with a revised schedule.

4. Discussion:

By letter dated March 14, 1979, JCP&L requested a schedule change for completion of the proposed sprinkler systems and hose station installations required by Table 3.1 of the NRC Safety Evaluation. In the sane letter JCP&L also requested that the requirements for the installation of thermally actuated, self closing valves in the diesel generator fuel oil lines be changed to the installation of a second fuel oil line to diesel generator no. 2. In subsequent discussions with the NRC staff, JCP&L was informed that a change to the Operating License would be necessary in order to allow proper consideration of the requested changes. The license change requested herein will allow proper consideration by the NRC staff and provides a mechanism for granting necessary changes ppovided that there is no undue risk to the health and safety of the '

public.

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Attachnent 1 Requested Chan?,e to Table 3.1 of the flRC Safety Evaluation 2294 ;29 i

TABLE 3.1 IMPLEMENTATION DATES FOR LICENSE

. PROPOSED FDDIFICATIONS Item Date 3.1.1 Fire Barriers December 1979 3.1.2 Fire Barrier Penetrations December 1979 313 Dm pers December 1979 3.1.4 Fire Detectors December 1979 3.1.5 Halon Suppression Systes December 1979 3.1.6 Water Spray Systems December 1979 3.1.7 Sprinkler Systms September 15,1979"*" I 3.1.8 Carton Dioxide Suppression System December 1979 3.1.9 lbse Stations September 15, 1979 3.1.10 Aqueous Film Forming Foam Completed 3.1.11 Portable Extinguishers Completed 3.1.12 Emergency Breathing Apparatus Completed 3.1.13 Rmoval of Cmbustible Material Cmpleted 3.1.14 Transformer Dike December 1979 3.1.15 Diesel Generator Fuel Oil Line December 1979 3.1.16 Ventilation System Changes December 1979 3.1.17 toss of Ventilation Alarm-Battery Room Cmpleted 3.1.18 Suppression System valve C,ntrol Completed 3.1.19 Portable Snoke Removal Equipnent Cmpleted 3.1.20 Alternate Water Supply to the Yard loop July 1980 3.1.21 Protection From Water Damage December 1979 I 3.1.22 New Battery Room and Rerouting Battery Cables Cmpleted 3.1.23 Remote Shutdown Station **

• • Schedule dependent on equipment availability (not to exceed end of 1980 refueling outage) 88"Except for the system extensions in the turbine build'ing condenser bay which shall be completed during the next refueling outage.

I 2294 60

Attachnent 2 Discussion of Requested Changes 2294 331 i

Introduction 9

In the course of implementing t.he Oyster Creek Fire Protecton Progran, new information and further evaluation have led to some changes in order to better the fire protection facilities. Also, sane changes were necessary in order not to adversely affect existing safety systems. These changes include a second fuel oil line to diesel generator no. 2 in lieu of the proposed thermally operated, self closing valves; installation of an automatic water spray system for the cable spread roan in lieu of the proposed halon system; installation of an automatic sprinkler system in the south end of the turbine building basement in lieu df the indicated (NRC SE Item 3 1.6) water spray system; and installation of a modified sprinkler system in the fire water pump house.

In addition to the changes indicated above, it is also necessary to request -

a change in schedule for the completion of the proposed sprinkler systems described in Section 3.1.7 of the NRC Safety Evaluation. This change is necessitated by the procurement situation described in the letter of March 14, 1979, from Mr. I. R. Finfrock, Jr. to the Director, Nuclear Reactor Regulation.

The following presents a discussion of the proposed changes to the Oyster Creek Fire Protection Program and the justification for each change.- Also presented is the basis for the. requested delay in schedule and the safety significance of such a delay.

2294 332 f

DIESEL GENERATOR FUEL OIL LINES As part of the Oyster Creek Fire Protection Program a commitment was made to install thermally operated, self closing valves in the fuel oil supply lines to the Emergency Diesel Generators. At that time it was believed that the supply lines were in a parallel configuration; therefore, the installation of the self closing valves would allow operation of the redundant diesel in the event of a fire. Further investigation has shown that the fuel oil supply line is common to both diesels. The installation of a thennally operated, self-closing valve to this line would render both diesel genertors inoperable upon closure; therefore, diesel generator reliability would be compromised to an unacceptable level in that onsite electric power must have sufficient independence, redundancy, and testibility to perform their safety function assuming a single active failure. Installation of a self closing valve in the conmon fuel oil line would introduce a single active failure event that would incapacitate both onsite. power sources.

As an alternative, it was decided to install a second fuel oil line to feed diesel generator No. 2 which will be isolable and independent of the fuel oil line to diesel generator No. 1. Also, it was decided to install manual isolation capability rather than thermally acutuated, self closing valves since the installation of this type of valve may result in a decrease in diesel generator reliability. Installation of the second fuel oil line will allow continued operation of one diesel generator should the other become involved in a fire. The new line will provide a means of isolating the main fuel oil storage tank frcm a fire in either diesel generator while still supplying fuel to the operable diesel generator. This will not only assure diesel generator reliability but also fulfills the intent of the thermally actuated, self closing valve commitment.

CABLE SPREADING ROOM FIRE PROTECTION Further study of the Fire Hazards Analysis for the Oyster Creek cable spreading room han resulted in a change in approach to fire protection in this area. Originally, it was ;'oposed to install an autcmstic total flooding halon system in order to provide rapid extinguishment of fires without presenting a hazard to personnel either in the area or those responding to a fire energency.

During the subsequent design stage of this system, it was found that in order to provide protection in the event of deep-seated fires within the cable trays a higher concentration of halon would be required than was previously planned. Consequently, the principal advantage of the halon system, personnel safety, would be negated. Also it was found that total flooding halon is not recommended for deep-seated fires by NFPA 12-A.

In light of the above and after consultation with our fire protection consultar.t it was decided to install an autcmatic, zoned water spray system tracing the existing cable trays in lieu of the halon system. This system will be more effective than the halon and will maintain the personnel safety objective. The effects of water runoff due to actuation of this system either in response to a fire or by inadvertant operation will be addressed in the design phase.

This change will increase the level of protection in this area and further assure the overall safety of the plant. As per the commitment to the NRC staff, design

+

2294 ;33

par cu ars (i.e. water spray density nmber anql spacing of nozzles, etc.) will be tranmitted as this infomation is dev, eloped.

'IURBINE BUILDING BASEMENT SPRINKLER SYSTEM The Oyster Creek Fire Protection Plan indicates that the south end of the turbine building basement will be protected .by an automatic sprinkler system in order to protect cables in this arec from the effects of an exposure fire. The NRC safety evaluation , lists this area under ;?oposed water spray systems; however, it was never intended that this system would be water spray.

Since safety related power cables traversing this area are routed in conduit, the major hazard is exposure to an area fire; therefore, a water sprinkler system, being more effective on this type hazard, was proposed.

By utilizing directional herds at specific junctions of cable trays, this system will also provide the protection committed to for the New Battery Room Installation.

Since the' main hazard in this area is exposure, the proposed sprinkler systs will provide the required protection for cabling in this area.

FIRE PUMP HOUSE FIRE PROTECTION Originally, it was proposed to install a sprinkler system in the fire water pmp house in order to protect the diesel driven fire pmps and their associated fuel oil tanks (located outside the building) frm the effects of fire. During the subsequent evaluation of this approach in the design stage, it was decided to install a pre-action sprinkler system inside the building for added reliability and a dry pipe deluge system over weather.

the fuel oil tanks in order to eliminate the possibility of freezing in cold

'Ihese systems will be installed by the June,1979 date; however, since the planned detection system will not be installed at this time, the pre-action and deluge valves will be installed in the open position. 'Ihe system will then be used as a wet pipe sprinkler system (closed fusible heads will be installed over the fuel oil tanks) until the proposed detection system is installed. At this time the pre-action and deluge valves will be connected to the detection system and the closed fusible heads over the fuel oil tanks will be replaced with open heads. The detection system will then actuate the pre-action and deluge valves upon sensing a fire condition thereby providing water to the sprinkler and deluge system piping for fire suppression.

This modified approach maintains the level of protection ccanitted to in the Fire Protection Program. Since measures are being taken to provide the required protection to this area by the June, 1979 date, no delay in schedule is involved and the health and safety of the public is not affected.

f SCHEDULE CHANGE The implementation of the Oyster Creek Fire Protection Progran has resulted in major changes in plant procedures and administrative controls which have not only significantly increased control of combustibles and ignition sources but also increased personal awareness of fire hazards and the measures taken to reduce such hazards. New and modified procedures require a permit for welding and cutting operations, fire watches under hazard conditions, restriction of smoking to designated areas, 2294 ;34 4

non-combustion generated smoke for leak testing, and the use of flame retardant materials where possible. Rese measures have b'cen effective in reducing fire nazards

' thrdughout the plant.

Even though the probability of a fire occurring has been reduced, other measures have been taken to mitigate the consequences should a fire occur. The station fire brigade has been increased from 3 to 5 members thus providing sufficient personnel to rapidly extinguish the fire, replace any menber that is incapacitated, and to supply vital support functions (i .e. , breathing air, caTrnunications, smoke renoval, etc.).

Be fire brigade members undergo a program of instruction designed to impart the necessary expertise to effectively extinguish fires in the most efficient manner possible. Should a fire be detected by station personnel, the fire brigade can be dispatched imediately which provides assurance that fire danage will be limited to the immediate area.

The measures taken above serve to reduce the probability of fire occurrance by reducing the.acce:ulation of combustibles and controlling ignition sources throughout the plant as well as providing competant and rapid response should a fire occur.

Although these and other administative controls (i.e. control of fire doors, staff augmentation, assigrrn!nt of organizational responsibilities, etc.) in conjunction with passive fire protecton features have provided a significant level of protection, it is recognized that additional means of detection / suppression are required. JCP&L has committed to major installations which will provide this additional protection.

Consequently, it was agreed that JCP&L will accomplish these modifications in accordance with the schedule contained in the NRC Safety Evaluation of the Oyster Week Fire Protection Progran and designated Table 3.1.

Be schedule contained in Table 3.1 of the NRC safety evaluation indicates that the proposed sprinkler system and Mse station installations will be completed by June, 1979; however, due to unforeseen circunstances these systems will not be complete by the indicated date. Being a Public Utility, JCP&L obtains services fran vendors through a competitive bidding process in order to assure that services are obtained as economically as possible in the interest of our consuners. In obtaining a vendor for the proposed sprinkler an hose station installations, it became necessary to ask the interested suppliers to subnit additional information in order to permit a responsible evaluation of their bids. At the present time a vendor has been selected and is proceeding with the modifications; however, due to the cime lost in the bidding process, the completion of these mcxiifications will require more time than allowed by the June,1979 date.

Sprinkler systems (and other water systems) have been proposed for the (1) Fire Water Pump House (pre-action and deluge), (2) outside of the west wall of the turbine building (deluge), (3) turbine building basement, (4) upper trays in the condenser bay, (5) Monitor & change area, (6) Reactor building elev.119', and (7) Reactor building elev. 75' ir} the area of the spent fuel cooling pumps. It is expected that items 1,2, 3, and 5 will be canplete by the June,1979 date; however, the canpletion of itens 6 &

7 as well as the hose station installations are dependent on the installation of a fire water header in the reactor building. Item 4 is an extension to an existing system and is scheduled for completion after the above modifications have been installed. Those systems that may not be completed by the June, 1979 date are the condenser bay extension to upper trays, the reactor building 119' & 75' elev. , and several hose station installations.

Re planned sprinkler systems for the 119' and 75' elevations of the reactor 2294 ;35

building will provide overall area protection for the 119' level and protection of the spent fuel pool cooling punps on the 75' level. nere is no safety related equipnent on the 119' elevation of the reactor building; therefore, a fire in this area will not affect the safe shutdown of the reactor. Ignition sources in this area are minimal during periods of normal plant operation since there are no process lines through this area, there is no operatirg machinery, and little if any maintenance activity. Bis area poses the greatest hazard during periods of plant shutdown wi.th attendent refueling activities. The sprinkler system planned for the 75' elevation provides protection against the loss of both fuel pool cooling pumps. No other safety related equipment is involved so that a fire in this area will not affect the safe shutdown of the reactor. Should a fire occur which would incapacitate the punps, sufficient time would be available to initiate cooling via the redundant, higher capacity system installed for the core off-loading during the 1977 outage period. A delay in the installation of these sprinkler systens will not present an undue risk to the health and safety of the public since the system for the 119' elevation will be complete prior to refueling operations and adequate means are available to assure cooling of spent fuel in the.cvent of a fire.

In conjunction with the proposed sprinkler systems, hose stations are scheduled to be installed on each level of the reactor building, outside the cable spread room, and outside the control room by the June,1979 date. All of these hose stations will be installed by this date with the possible exception of those on the 75 ', 95', and 119' elevations of the reactor building. Be probability of fires in these areas has been significantly lessened by the aforementioned administrative controls. Even if such a fire were to occur the continuity of combustibles, location of safety related equipnent, and actions required to mitigate the event are such that safe shutdown of the reactor would not be impeded. As mentioned above there is no safety related equipment on the 119' level of the reactor building. Credible fires would be of a class A type and sufficient portable extinguishers are available in this area to provide for extinguishment. B e only safety related equipment on the 95' elevation are the liquid poison system and the isolation condensers. Due to the lack of continuity of combustibles, the maximun credible fire would not involve both of these systems, and furthermore , neither of these systens is required for safe shutdown.' Safety related equipment on the 75' elevation consists of the fuel pool cooling system (discussed abov e) , reactor protection instrunent racks, and isolation condenser valves. We only combustible material in the area of the spent fuel pool cooling system is the cable insulation above the punps. As discussed above a redundant system exists approximately 20 feet away. A fire engulfing the cables above the pumps would not affect the redundant system since the cables for this system are run in rigid conduit by a different route; therefore, fuel pool cooling is assured. Although a fire could incapacitate the isolation condenser system, this system is not required for safe shutdown.' The reactor protection instrunent racks are separated by distance and lack of continuity of combustibles such that a fire would not incapacitate both racks. Be loss of either rack muld not prevent safe shutdown. It is therefore concluded that a delay in tige installation of the aforementioned hose stations will not adversely affect the health and safety of the public.

The remaining system that may not be installed by the June,1979 date is the additional sprinkler piping for the upper cable trays along the west wall of the condenser bay. This area is protected by an existing sprinkler system at present and the fire loading in this area is low; therefore, the major hazard to these cables is a fire originating within the tray itself. A fire in these cables may affect the availability of emergency powr; however, the normal shutdo e systems for the reactor would not be affected. The loss of the cables in this arep would not affect rod insertion and various means of heat removal would be available (i.e. bypass to main condenser, shutdown cooling, emergency condensers).

22H 136

• In relation to a fire emergency

Another problem associated with the insta11*ation of additional sprinkler piping in

• this area is radiation exposure to personnel. An analysis based on radiation surveys have shown that exposures could run as high as 160 man-rem although it is more probable that they would be in the area of 50-75 man-rem. If this work were to be ceccrnplished during a shutdown period radiation exposure ceuld be reduced to very low levels. In light of the ALARA obje_ctives and since a fire in these cables would not affect the safe shutdown of the plant," assuring the health and safety of the public, it is proposed to install this system during the next refueling outage.

In summary, the requested schedule changes will not adversely affect the health and safety of the public. Administrative controls and an augmented fire brigade assure that the occurrance of a fire is a low probability event and that should a fire occur adequate personnel are available to mitigate the consequences. Finally, even though a fire might develop in these areas where system installation may be delayed, the ability to safely shutdown the plant will not be jeopardized and therefore the health and safety of the public is protected.

"In relation to a fire emergency 2294 a37 f