ML20093E273

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Suppls 830916 Request for Schedule Exemption from 10CFR50, App R & 10CFR50.48(c)(3).Request Removes Some Fire Zones, Provides List of Sys Affected in Fire Zones & Provides Compensatory Measures Consistent W/Nrc Guidance
ML20093E273
Person / Time
Site: Oyster Creek
Issue date: 07/11/1984
From: Fiedler P
GENERAL PUBLIC UTILITIES CORP.
To: Crutchfield D
Office of Nuclear Reactor Regulation
References
NUDOCS 8407170444
Download: ML20093E273 (41)


Text

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CEU Niiij4&T COipOi&UOn

' Nuclear

g=ra88 Forked River. New Jersey 08731-0388 609 971 4000 Writer's Direct Dial Number

July 11,1984 Mr. Dennis M. Crutchfield, Chief Operating Reactors Branch #5 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Dear Mr. Crutchfield:

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Appendix R - Schedule Exemption Request By my letter dated September 16, 1983, GPU Nuclear Corporation requested a schedule exemption f rom 10 CFR 50.48(C)(3) of the regulations. Thia request resulted in several meetings with your staff and GPUN personnel which effected a revision of our September 16 submittal. The attached replaces in its entirety our original submittal.

Revisions include (1) removal f rom the submittal those fire zones which are not in Appendix R non-compliance, (2) providing a specific listing of those systems powered f rom both off site and on site that will be affected or unaffected in each fire area / zone, and (3) providing compensatory measures that are consistent with the guidance provided by the NRC.

It should be noted that in the unlikely event that a fire occurs in RB-FZ-lD, TB-FZ-llB or TB-FZ-llc and the supplemental procedure for cold shutdown is in effect as discussed in Appendix A of this submittal, it will be at the discretion of the Group Shif t Surervisor (CSS) as to whether the plant will be taken to cold shutdown or remain on the isolation condenser. The longterm negative effects of injecting fire water into the vessel as the interim measure for achieving cold shutdown does not outweigh the advantage of remaining on the isolation condenser until those systems normally required for cold shutdown are repaired.

8407170444 840711 I

PDR ADOCK 05000219 L

F PDR gf7W Li g

i GPU Nuclear Corporation is a subsidiary of the General Public Utdities Corporation

r Mr. Dennie M. Crutchfield, Chisf U.S. Nuciser R gulitory Commiccion Page 2 Questions concerning this submittal should be directed to Mr. Michael Laggart, Manager - BWR Licensing, at 201-299-2341.

Very truly yours, l,) A2 )

edler ~ _ _ _ _ _

Vice President and Director Oyster Creek slf:0308e Attachment ec: Administrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 NRC Resident inspector Oyster Creek Nulcear Generating Station Forked River, NJ 08731

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OYSTER CREEK NUCLEAR GENERATING STATION JUSTIFICATION FOR APPENDIX R SCHEDULE RELIEF CPU Nuclear Corporation 100 Interpace Parkway Parsippany, New Jersey 07054 4

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OYSTER CREEK NUCLEAR GENERATING STATION JUSTIFICATION FOR APPENDIX R SCHEDULE RELIEF TABLE OF CONTENTS SECTION PAGE

1.0 INTRODUCTION

1 2.0 FIRE PROTECTION SYSTEM AND PROGRAM ADEQUACY 2

3.0 CONSEQUENCE ANALYSIS 5

3.1 Methodology to Develop Justification for Schedule Relief 5

3.2 Justification for Schedule Relief; Discussions 6

l 4.0 ENGINEERING OF REQUIRED MODIFICATIONS 12 5.0 OUTAGE RELATED EFFORTS OTHER THAN APPENDIX R REQUIRED MODIFICATIONS 14 l

6.0 CONCLUSION

S 15 l

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7.0 REFERENCES

16 APPENDIX A - Justification For Schedule Rdlief Tables APPENDIX B - Table Of All Fire Areas / Fire Zones Evaluated APPENDIX C - Tentative Mods During '85 Outage

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Page 1 of 16 i

1.0 INTRODUCTION

On June 30, 1982, GPU Nuclear (GPUN) submitted to the Nuclear Regulatory Commission (NRC) the Oyster Creek Nuclear Generat-ing Station (OCNGS) Appendix R Fire Evaluation Report (Refer-ence 1).

The subject report documented the results of an assessment of the fire protection features at OCNGS for con-formance to the requirements of Appendix R to 10CFR50 and included recommended modifications to meet the requirements.

It should be noted that during this evaluation the exact locations of certain shutdown cables could not be deter-mined. Thus specific recommendations could not be made for these cases. GPUN has recently determined, during this cur-rent plant outage, the exact locations of the remaining cir-cuits using the audible signal testing and visual verifica-tion methods and revised the June 30, 1982 submittal to designate the specific modifications and accompanying exemption requests required to achieve compliance with Appendix R.

'Also included with the June 30, 1982 submittal was a schedule for completing the modifications required to bring the plant in compliance with the requirements of Appendix R.

The pro-posed schedule required more time than the provisions per-mitted by 10CFR50.48 primarily due to the fact that exact i

locations of shutdown circuits had to be determined before specific modifications could be proposed, approved and imple-mented.

On 2/16/83, the NRC indicated that in order that schedule relief be granted, justification must be provided that will ensure safe plant operation during the exemption period.

It is the purpose of this report to provide this justification.

Sections 2.0 and 3.0 of this report provide the justifiestion for each fire area / zone not in compliance with the Appendix R requirements as indicated in our submittal of June 30, 1982.

Sections 4.0 and 5.0 provide the rationale for our inability 4

to meet Appendix R Schedule requirements.

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Page 2 of 16 r

2.0 FIRE PROTECTION SYSTEM AND PROGRAM ADEQUACY GPU Nuclear believes the current fire protection system and program as well as emergency procedures in place at Oyster Creek provides reasonable assurance that a fire anywhere in the plant will not prevent the plant frem achieving hot and cold shutdown. The reasons for this are twofold:

A.

A recent NRC safety inspection conducted by Mr. A. E.

Finkel (Reference Letter dated May 20, 1982,

Subject:

Inspection No. 50-219/82-07) attested to the adequacy of the plant fire protection program with respect to Ad-ministrative Controls, Fire 0,perating Procedures, Fire Brigade Training and Drills, Qualified Fire Brigade Personnel and Fire Protection Modifications to the plant. No violations were found.

B.

The analysis that follows later in this report, Appendix A, provides reasonable assurance that in most fire areas / zones where modifications to eliminate Appendix R noncompliances are required (Reference 7.1), adequate fire protection and suppression features currently exist to ensure safe plant shutdown, except in those areas / zones noted in section 3.2 and Appendix A.

lfodifications will be undertaken dur ing.the current plant outage, to ensure safe plant shutdown in the event of a fire in those areas / zones where existing fire protection and suppression features are not adequate.

In addition, procedural guidelines will be in place for restart (symptom oriented Emergency Operating procedures) or conriauous tire watches will be posted.

A summary of justificationr for schedule relief in vari-ous fire areas / zones from the consequence analysis is given here 'for a quick understanding of the bases for justifying safe shutdown in each fire area / zone.

The following categories have been used for justifica-tion:

(1)

Lack of Combustibles A review of the fire area / zone indicates a low level of combustibles making the risk from a fire sufficiently low.

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Page 3 of 16 (2)

Sufficient Fire Protection Features A review of the fire area / zone indicates that sufficient fire detection and/or automatic I

suppression features exist to make fire propagation to unacceptable levels unlikely.

I (3)

Alternate Shutdown Systems A review of the fire area / zone indicates that unaffected alternative systems are available for use in lieu of the lost function.

The alternate system can be utilized by the operator in con-junction with the plant emergency procedures (EOPS, Reference 2) to recover the lost func-tion (s).

(4)

Temporary Rerouting or Protection Provided A review of the categories above provided no justification for schedule relief. Temporary rerouting or protection is required for schedule relief.

(5)

Continuous Fire Watch or Supplemental Procedures to EOPS/or Continuous Fire Watch Until Supplemental Procedures in Place An individual vill be continuously present to detect and respond to any fire emergency.

This provides reasonable assurance that a fire will be discovered in its initial stages before significant damage occurs and will be suppreesed manually by either the fire watch or the plant fire brigade ; or supplemental procedures to the E0PS will be implemented which provide capability to achieve cold shutdown; or a continuous fire watch will be provided until supplemental procedures discussed above are in place.

Page 4 of 16 1

Summary of Justifications The justifications for Schedule Relief are summarized as follows:

Fire Area / Zone Designation Description Justification FZ-ID Reactor Building, elevation 51' 1,2,3,5 FZ-1E Reactor Building, elevation 23' 1,2 FA-3A IC 4160V Emergency Switchgear Vault 3

FA-6 480V Switchgear Room 2

i FZ-8A MG Set Room, elevation 35' 1,2 I

j FZ-8C A&B Battery Room, Tunnel and Tray Room 1,2 i

FA-9 office Building 1,3 J

l FZ-10A Monitoring and Change Room Area 1,2 l

FZ-118 Turbine Lube Oil Storage, Pumping 2,3,5 i

and Purification Area FZ-11C Switchgear Room, west end of 3,4,5 Turbine Building on Mezzanine Level FZ-11D

. Basement Floor South End 1,2 l

FZ-11E Conder.ser Bay 1,2 j

FA-14 Circulating Water Intake 1,5*

)

  • The Intake Structure is continuously monitored oy security l

guards.

In addition the area is provided with 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> video surveillance by plant security.

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3.0 CONSEQUENCE ANALYSIS 3.1 Methodology to Develop Justification for Schedule Relief f

The following is a description of the methodology used to prepara justifications to support the Appendix R i

modification schedule:

l Updated the original Appendix R Fire Evaluation

.i.

(1)

{

Table (Ref. 7.1 b) which lists the Appendix R l

non-compliances by fire area / zone including the lost protective function, af fected trays / conduits and drawing reference. This update incorporated I

the reduced

  • number of safe shutdown circuits identified by GPUNC since the issuance of the l

original Appendix R Fire Evaluation Report as well as the results of the recently completed audible signal testing and visual verification task which determined the exact routing of the remaining circuits.

(2)

Identified alternate systems, components and j

related auxiliaries previously cited in the Ap-l pendix R Fire Evaluation Report Table in addition j

to non-safety systems, components and auxiliaries not considered in the original Appendix R Fire j

Evaluation.

i (3)

Performed a detailed consequence analysis of each

]j fite area / zone. The. amount of combustibles, fire protection features (i.e., detection, automatic suppression, manual. hose stations), shutdown systems that may be subject to degradation, and alternate system that are physically separated, including their electrical power and control j

circuits were considered in the analysis.

1 (4)

Based on the results of step (3) above, prepared

.L detailed justification to support the Appendix R

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sodifications schedule. These justifications are summarised and described below in Section 3.2.

]

For all fire areas / sones containing shutdown systems that could be subject to degradation which are not provided with existing fixed automatic supression ' systems, interia measures j

consisting of procedural guidelines for plant operations to control the affected system f

functions were provided in accordance with plant

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emergency procedures, "EOPS" (Reference 2).

Additional interia measures such as continuous fire watch or supplemental procedures to modify the E0PS to demonstrate a means to get to cold shutdown or a continuation of both were proposed.

J

  • Number of circuits was considerably reduced as a result iof GPUN's detailed evaluation of control logic elementary and electrical power distribution drawings.

3.2 Justification for Schedule Relief; Discussions l

The following is a brief discussion of the findings in each -

fire area / zone including justifications for schedule relief.

1 For a tabular summary including procedural guidelines see Appendix A.

s (1)

Fire Zone (FZ-lD) - Reactor Building, Elevation 51' The systems subject to degradation from a fire in this

]

zone are identified in Appendix A of this report. Also indicated are the systems that are unaffected by the i

fire. Justification for schedule relief is based on j

the following:

1 a.

Reactor Scram is unaffected thus assuring 4

i Reactivity Control.

i b.

Alternate systems are available to provide 3

RC Makeup, Decay Heat Removal and Support-i ing Functions.

l c.

Minimal degradation of the systems in this l

fire zone due to the low combustible load-ing and existing automatic detection and suppression systems which will. activate to l

protect safe shutdown circuits in cable j

t ray s.

d.

Emergency Procedures (EOPS) are utilized by the operator to compensate for any lost monitoring parameters or systems to bring the reactor to hot shutdown.

e.

A continuous fire watch will be provided in the fire zone or supplemental.

4 procedures will be provided to suppicaent a

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Page 7 of 16 the E0PS to demonstrate a means to get to cold shutdown or a continuous fire watch will be provided until the aforementioned supplemental procedures take effect.

(2)

Fire Zone (FZ-1E) - Reactor Buildina, Elevation 23' As indicated in Appendix A, all shutdown systems contained in the reactor building are subject to degradation. However, the existing automatic detection and suppression system protecting cable trays in this fire zone will activate to protect the vulnerable systems until extinguishment. Therefore no loss of safe shutdown capability will occur.

No interin measures are required.

(3)

Fire Area (FA-3A) - Turbine Buildina, 4160V ES SWGR - IC The only shutdown system lost by a fire in this ares is the Drywell Cooling System. All other systems contained in this fire area have redund-ant trains contained in the adjacent fire area, FA-38.

Since this is the only nonredundant safe shutdown system affected, the operator can uti-lize alternate systems that are unaffected by a fire in this area to achieve safe plant shut-down. Therefore, justification for_ schedule relief is based on the availability of alternate systems.

(4)

Fire Area (FA-6) - 480V Switchaear Room As identified in Appendix A, many systems, both

' safety grade and_non-safety grade, are subject to degradation by a fire in this area. However, the existing automatic detection and suppression system protecting this fire area will activate to protect the vulnerable systems-until extinguishment.

Therefore, no loss of safe shutdown capability will occur.

No interin measures are required. Justification for schedule relief is based on existing fire protection features.

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Page 8 of 16 (5)

Fire Zone (FZ-8A) - MG Set Room As indicated in Appendix A, the number of systems subject to degradation are small and many unaffected systems exist.

However, the existing automatic suppression system protecting the fire zone will activate to protect the vulnerable systems until extinguishment.

Therefore no loss of safe shutdown capability will occur. No interim measures are required.

Justification for schedule relief is based on low combustible loading and existing fire protection features.

(6)

Fire Zone (FZ-8C) Battery Room, Tunnel, Electric Tray Room As indicated in Appendix A, many systems are subject to degradation by a fire in this zone.

However, the existing automatic detection and suppression system protecting the fire zonu will activate to protect the vulnerable systems until extinguishment. Therefore, no loss of safe shutdown capability will occur.

No interim measures are required. Justification for schedule relief is based on low combustible loading and existing fire protection features.

4 (7)

Fire Area (FA-9) Of fice Building The only shutdown systems subject to degradation by a fire in this area are the ADS (two EMRV's) and the Shutdown Cooling systems.

Since all other shutdown systems are unaffected by a fire in this area, the operator can utilize the un-affected systems as directed in the emergency procedures (EOPS). Justification for schedule relief is based on the availability of alternate systems utilized in conjunction with the emer-gency procedure and the low combustible loading j

in this fire area.

(8)

Fire Zone (FZ-10A) Monitoring and Change Room Area The systems subject to degradation f rom a fire in this zone are identified in Appendix A of this report.

However, the existing automatic

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detection and supression system protecting this f

L sone will activate to protect the vulnerable j

l systees until extinguishment. Therefore, no loss of safe shutdown capability will occur.

No j

interie measures are required.

Justification l

for schedule relief is based on low combustible loading and existing fire protection features.

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(9)

Fire Zone (FZ-115) Turbine Lube Oil Storage.

Pumping and Purification Ares l

As indicated in Appendix A of this report, many

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safety grade shutdown systems located in the reactor building are subject to degradation.

However, the operator can utilise the unaf fected systems cited in Appendix A in conjunction with i

plat emergency procedures to bring the reactor i

to hot shutdown.

In addition, a continuous l

firewatch will be provided in the fire sone or supplemental procedures will be provided in

[

addition to the 30FS to demonstrate a means to l

get to cold shutdown or a continous fire watch will be provided until the aforementioned supplemental procedures take effect. The refore, justification for schedule relief is based on availability of alternate systems utilised in conjunction with plant energency procedures, and the additional proposed interie seasures as described above.

(10)

Fire Zone (F1-11C) Turbine Bu11dina Switchaear Area. Messantne As indicated in Appendix A of this report, eeny f

safety grade shutdown systems are subject to i

degradation. A fire in this sone may affect the l

onsite and offsite electrical power systems.

l Since the only fire protection in this some is automatic detection with manual hose capability a rerouting is required for schedule relief justification.

In review of the electrical j

circuitry in this sone, one train of the onsite

.i essential power system will be preserved by rerouting four (4) circuits out of F1-11C. This modification would provide the operator with the capability to bring the reactor to hot shutdown utilising emergency operating procedures.

In I

addition, a contir.uous fire watch will be i

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Page 10 of 16 provided in the fire zone or supplemental procedures will be provided in addition to the E0PS to demonstrate a means to get to cold shutdown or a continuous fire watch will be provided until the aforementicned supplemental procedures take ef fect. Justification for schedule relief is based upon the rerouting of I

essential power circuits, availability of alternate systems utt11:ed in conjunction with plant emergency procedures and the additional interin measures as described above.

(11)

Fire Zone (FZ-11D) Turbine Building South End Basement l

Appendix A identifies systems that are affected by a fire in this zone.

However, the existing c

i automatic suppression systen protecting this l

fire zone will activate to protect the l

vulnerable systees untti extinguishment therefore, no loss of safe shutdown capability l

will occur. No interie measures are required.

l Justification for schedule relief is based on low combustible loading and existing fire protection features.

(12)

Fire Zone (FZ-11E) Turbine Building Condenser Bay The systems subject to degradation and unaffected systems are identified in Appendix A.' However, the existing autoestic suppression system protecting this fire sone will activate to protect the vulnerable systems untti extinguishment. Therefore, no loss of safe shutdown capability will occur.

No interin measures are required. Justification for schedule relief is based on low combustible loading and existing fire protection features.

(13)

Fire Area (FA-14) Circulating Water intake The systees subject to degradation in this area are identified in Appendix A.

Since all circuitry is in conduit, the combustible loading is low, and some degree of separation exists between the two unit substations, the probability of a fire in this area degrading the systems identified in Appendix A of this report

i Page 11 of 16 is low. This area is continuously monitored by security guards located at a guard house designated for the intake structure.

In addition, the area is provided with 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> video surveillance by plant security.

Justification for schedule relief is based on low combustible loading at the intake structure and existing surveillance of the structure as l

described above.

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i Page 12 of 16 4.0 ENGINEERING OF REQUIRED MODIFICATIONS As noted in the NRC's safety evaluation report dated November 18, 1982 (Letter 1.S05-82-11-063), Oyster Creek has undergone an evaluation in accordance with the requirements of Section III.G and III.L of Appendix R, and has identified non-compliances and proposed modifications in combination with exemption requests which we believe to be justifiable and consistent with sound fire protection engineering prac-tices. Appendix B is a list of all fire areas which have been evaluated. This table presents GPUN's disposition as defined in the initial report submitted on June 30, 1982, plus a clarified position with respect to specific exemption requests for each fire area and fire zone. (Note that these exemption requests reflect a general position with respect to exemption requests. The updated reports (Rev. 2) relate exemptions requested based upon each non-compliance.

Proposed modifications in order to comply with Appendix R I

will consist of cable rerouting or imposition of fire barriers to eliminate noncompliances.

Some fire barrier modifications will be combined with specific exemption requests if the situation necessitates it.

In addition, an alternate shutdown facility will be designed for fires, which occur in the Control Room or Cable Spreading Roo:n.

GPUN has completed an extensive field effort to determine the exact routing of shutdown circuits.

Conceptual design of the modifications outlined in our May submittal is currently being done.

Detailed engineering can then proceed with respect to extent of fire barrier coverage and/or cable rerouting and the selection, procurement and location of new equipinent.

In addition, the scope of work identified in the evaluation shall include the desiPn of those modifications for which an exemption is requested. Cable rerouting may not eliminate the need for fire barrier protection as rerouting may consti-tute removal of redundant circuits from the same tray or conduit but not necessarily removat to a separate fire area or zone in which case one train may still require a fire barrier. Upon completion of this effort, a cable derating study as well as a study to deter'nine the adequacy of the existing tray and conduit supports to accommodate the addi-tional deadweight load imposed by the fire barrier must be performed.

Both dorating and supports analyses, and appro-priate modifications, if required, must be completed for plant safety purposes prior to imposing fire barriers.

-5,.,,

Page 13 of 16 r,When the scope of both fire barrier and cable rerouting is

' comple'ce, engineering can be performed in parallel with ef-

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forts to reinforce tray and conduit supports. Again, in order not to ecmpromise plant safety, cable rerouting and tray and ' conduit support reinforcement will be performed

- during the cycle 11 outage.

Fire barrier installation will then proceed with completion scheduled prior to startup.

The attached schedule for Appendix R modifications provides information on various elements of the project and their progression until completion of all the related tasks in Cycle 11.

It can be seen from this schedule that Oyster

[

Creek's compliance with Appendix R will gradually and continuously improve and will be in full compliance before startup.after Cycle 11 refueling outage.

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GPUN proposes deferral of Appendix R modifications for all plant areas to the Cycle 11 outage, in accordance with the attached schedule.

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Page 14 of 16 5.0' OUTAGE RELATED EFFORTS OTHER THAN APPENDIX R REQUIRED MODIFICATIONS Considerable effort has been spent in defining the total l

number of modifications which GFUN believes is reasonably achievable during the Cycle 10 outage. Our letter of December 24, 1981, indicated that the total number of items which had been identified up to this date " exceeded any reasonable ability to manage the outage".

Furthermore. "the original outage scope would constitute a potential overall j -

safety problem, and ALARA and safety concerns would not be properly served by proceeding as originally planned".

i It is evident from previous correspondence with the commis-sion regarding the necessity to. defer a number of NRC re-quired modifications that the commission recognizes the logistical constraints on manageability placed upon GPUN due to the magnitude of effort required in the current outage.

The present plans do not incorporate any provisions for Ap-pendix R modifications during the current outage except for fire zone FZ-11C where circuits will be rerouted to preserve the on site electrical distribution system.

Should the sche-dule exemption be denied for an item not requiring NRC ap-proval and requiring a plant shutdown,. deferral of other outage work may be required. Due to the nature of the anti-cipated Appendix R modifications such as cable tray and con-duit fire barriers, and cable rerouting throughout.the plant, scheduling these modifications concurrent with already.

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planned'non Appendix R modifications could interfere with the timely completion of the. planned NRC modifications as well as i

planned safety and operational items, plant maintenance, i-inspections and upgrades.

Appendix'C provides a preliminary list of modifications planned for Cycle 11 outage along.with Appendix R modifica-tions. The modifications are selected using an' established priority assignment method based on. safety, plant operational and performance concerns, resources availability, etc.

conside{coions.

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Page 15 of 16 6.0-CONCLUSION For the_ reasons specified in items 4.0 and 5.0, GPUN be'ieves it is. impractical to plan for completion of required Appendix R modifications during the Cycle 10 outage as the workload for this outage has already been scaled down with deferral of specific NRC initiated non Appendix R modifications due to manageability problems.

In addition, the engineering re-quired to support the ef fort to define a complete work scope could not proceed effectively until the Cycle 10 outage be-gan.

For these reasons, CPUN requests deferral of imple-mentation of Appendix R modifications to the Cycle 11 outage.

Technical justification to support plant restart and operation between the Cycle 10 and 11 outages without complete implementation of Appendix R modifications is provided in section 3.0 and Appendix A.

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Page 16 of 16

7.0 REFERENCES

The following references were used for preparing this Justi-fication for Appendix Scheduler Relief:

1.

a.

GPUN letter to Mr. D. Crutchfield dated June 30, 1982, " Fire Protection 10 CFR 50.48" b.

GPUN letter to D. Crutchfield dated December 16, 1983 " Fire Protection 10 CFR 50.48" c.

CPUN letter to D. Crutchfield dated May 3, 1984

" Fire Protection 10 CFR 50.48" 2.

Symptom Based Emergency Procedures (EOPS) per Rev. 2 of Generic BWR Emergency Procedure Guidelines, EMG 3200.01 thru 08, Drafts.

3.

NRC letter LS05-82-11-063 dated November 18, 1982.

D. Crutchfield to P. B. Fiedler, " Safety Evaluation Report for Appendix R to 10 CFR 50 Items IIIG and IIIL

- Oyster Creek" 4.

GPUN letter to NRC dated December 24, 1981, " Cycle 10 Refueling Outage" 5.

NRC letter LS05-82-07-076 dated July 30, 1982.

D. Eisenhut to P. Clark, " Request for Deferment of Items Which GPU Nuclear Corporation Had Previously Committed to Accomplish Durint; the 1982 Cycle 10 Oyster Creek Refueling / Maintenance Outage" 6.

GPUN letter to D. Eisenhut dated December 29, 1983,

" Cycle 10 Refueling Outage" 7.

Oyster Creek Outa,ge Technical Functions Contract Status as of January 8, 1983 r

a

GPU Nucirr APPDOIX A Rev12 ion 1 Oyst:r Creek Nucirr Cenertting St tion JUSTIFICATION FOR SCHEDULE RELIEF TABLES l

FIRE S/D SYSTEMS SUBJECT NOTE NOTE I

LOCATION lPRESENTFIREPROTECTIONSTATUS TO DEGRADATION 1

HNAFFCCTED SYSTEMS 1

INTERIM K ASURES l

l ITEM AREA / ZONE 1

l

' 1.

RB-FZ-ID Reactor Combustible loading is low.

Safety Systems-Onsite Safety Systems-Onaite Power The reactor can be brought to I l

Building Existing detection and Power hot shutdown with the unaf-l l

El. 51' automatic del >ge water spray Reactor Scram 1

fected onsite powered systems I

protection for cable trays Isolation Condenser 3

MSIV's 5

by utilizing the Emergency Op-l (1005 tray coverage) will Core Spray 2

Containment Spray 5

erating Procedures as follows:

1 minimize fire damage IRM's 4

Emergency Service Water (ESW) 5 l

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Rx Fuel Zone Level 4 l Fire Water

  • 2,5 Procedural Guidelines (EOPS) !

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l EMRV's 3 lDrywell Pressure 4

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l lRBCCW 5

Cleanup (Isolation) 5

1. Evaluate entry conditions l

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lRPV Level & Pressure 4

Rx Recirculation (Trip) 5 of the symptom based emer-l l

l Shutdown Cooling l3 Electrical l5 gency procedures (EOPS) EMGl l

l l (Components & RBCCW)I Service Water (SWS) l5 3200.01. If the entry I

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lDrywell Cooling l5 Condensate Transfer 5

conditions are satisfied, I

I l (RBCCW) l Containment Monitoring 4

follow procedure EMG l

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CRD Hydraulic 2

3200.01 RC/L, RC/P and RC/0 l

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RPV Level & Pressure (Local) 4 utilizing systems unaffec-1 Isolation Condenser (Hanual) 3 ted by the fire in this l

zone. If the entry condi-l

. Non-Safety System-Offsite Power tions are not satisfied, I

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l follow normal shutdown Turbine Bypass System (TBS) 3,5 procedures.

Circulating Water 5

Condensate 2

NOTE:

l Feedwater 2

l TBCCW 5

A) If RPV level cannot be l

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determined, RPV Flooding l

l 1s required. Enter pro-l l

cedure EMG 3200.08, RPV i

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l Flooding. If the EMRV's are unavailable and remain in the closed pusition, follow procedure ENG I

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3200.01 RC/P-2 to re-l l

establish pressure control l

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l utilizing the systems un-l l

l affected by the fire in l

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this zone.

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B) If any EMRV is cycling, I

l enter procedure EMG 3200.01 l

l RC/P-1.

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2. Complete evaluation of I

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l entry conditions for EM; l

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3200.02, Containment Con-I l

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l trol cannot be determined l l

l because circuits and com-l l

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  • Thi2 ty;. tem has an independent power supply and does not require onsite or offsite poder to operate.

NOTE la Safety functinn Legend -

1.

Reactivity Control 3.

Decay Heat Removal 5.

Supporting Functions 2.

RC Makeup 4.

Process Monitoring Page 1 of 13

GPU Nuc1;ar.

APPEWIX A Revition 1 Dyst;r Creek Nuclxr Genersting Stcti JUSTIFICATION FOR SCHEDULE RELIEF TABLES FIRE S/D SYSTEMS SUBJECT

. NOTE i NOTE l

IITEMAREA /ZOK LOCATION PRESENT FIRE PROTECTION STATUS TO DEGRADATION 1

UNAFFECTED SYSTEMS 1

INTERIM K ASURES I

l l 1. (RB-FZ-lO Reactor H

ponents for torus water 1

(Cont'd)

Building 1

temperature and drywell l

El. 51' i

i temperature were not il l

identified in the origirn!

l Appendix R Fire Evaluation.

l l

l l

Since the othe parameters,l l

l l

Torus water level and dry-1

' I-l well pressure have been

l l

considered and are un-I affected by the fire in this zone, utilize systems identified in SP/T-2 and I

i DM/T to assure Containment i l

Control. The impact on I

containment control may be created by a stuck open or l

I spuriously actuating EMRV l

or E MV's which cannot be l

l l

opened.

l I

.i Because cold shutdown cannot' be achieved utilizing the I

l lEDPs alone, GPUNC will eithert l

1 I

l l;

A. Post a continuous fire watch.

B. Develop and implement a I

supplemental procedure in l

I addition to the E0Ps which l

l l

provides the capability to

.l l

l l

achieve cold shutdown.

l l

1 l

C. Post a continuous fire I

l ll l

watch until the supplemen-l tal procedure is developed.

I 2. lRB-FZ-1E l Reactor l Combustible loading is low.

l Safety Systems-Onsitel l Safety Systems-Onsite Power l1. The existing detection ll l

l l Building l Existing detection and auto-l Power l

l l

and automatic suppression l l

I lEl. 23' lmatic deluge water spray (pro-l l

l Fire Water

  • 25l systems are considered I

ltection for cable trays 1005 IReactor Scram i1 l Service We'.er

$I adequate to limit damage l

tray coverage) will minimize Isolation Condenser 3 l Condensate Transfer 5 l and protect the vulnerable I

fire damage.

CRD Hydraulic-2 l Electrical (Offsite Power) 5 l systems. Therefore, in-l Core Spray 2 IRPV Level & Pressure (Local) l4 l terin measures are not l

l EMRV's 3 l Reactor Scram (see text) l1 l required.

l l

l IElectrical l5 lESW (Manual) l5 l l

l l

l l Containment Spray l5 IMS Isolation (Manually Isolate)l 5 l l

.l l

l l

ESW 5

Isolation Condenser (Manual) l3 l l

l l

l.

'I IRM's 4

Core Spray (Manual) l l

l I

I I

l l

11 I

I l

SThiD rystem has an independent power supply and does not require onsite or offsite power to operate.

NOTE 1: Safety Function Legend -

1.

Reactivity Control 3.

Decay Heat Removal 5.

Supporting Functions i

2.

RC Makeup 4.

Process Monitoring Page 2 of 13

4PU Nuclear APPEWIX A Revirion 1 Myster Creek Nuclear Gener; ting Stction JUSTIFICATION FOR SCHEDULE RELIEF TABLES l

FIRE S/D SYSTEMS SUBJECT NOTE NOTE I

ITEM AREA /ZOE LOCATION PRESENT FIRE PROTECTION STATUS TO DEGRADATION 1

UNAFFECTED SYSTEMS 1

INTERIM EASURES l'

I 2.

RB-FZ-1E

' Reactor l Rx Fuel Zone Level 4

Drywell Cooling (Mamal)

(Cont'd)

Building LMain Steam Isolation 5

Containment Monitoring 4

El. 23' Shutdown Cooling 3

Cleanup (Isolation) 5. Non-Safety System-Offsite Power lDrywell Cooling l5 l

lRBCCW I5 Feedwater 2 l l

RPV Level & Precsure 4

Condensate 12 l

l Circulating Water 15 l

l Non-Safety System-Turbine Bypass System (TBS) l3,5 l

l l

Offsite Power TBCCW l5 l

[

Rx Recirculation 5

l 3.- TB-FA-3A - l Turbine Limited combustible loading and Safety Systems-Onsite Safety Systems-Onsite Power The reactor can be brought IBuilding presence of a detection system Power to cold shutdown with the l

l4160V and manually actuated CO2 lDrywell Cooling Reactor Scram l1 l unaffected onsite powered l

lSWGR-IC system will provide prompt I

5 CRD Hydraulic l2 l systems by utilizing the l

l extinguishment of a fire.

l~

Core Spray 12 l Emergency Operating Procedures l l

-l l

EMRV's l3 las follows:

l I

Containment Spray 5

Emergency Service Water 5

A fire in this area will not

)-

(ESW) affect the safe ehutdown of l

l l

Electrical 5

the plant. Loss of the Dry-l-

l l

IRM's 4

well Cooling Units will not i

Mein Steam (Isolation) 5 create an entry condition to Containment Monitoring 4

EMG 3200.01 or 02. Therefore, Rx Fuel Zone Level 4

the operator should be con.

RPV Level and Pressure 4

cerned with extinguishing the l

l Shutdown Cooling 3

fire and continue normal oper-l l Cleanup (Isolation) 5 ation until a determination l

lRBCCW 5

can be made as to the denege Fire Water *-

2,5 in this area. If the entry Service Water (SWS) 5 conditions to procedure EMG Condensate Transfer 5

3200.02 Containment Control

.I are satisfied, utilize systenal Non-Safety System-Offsite Poweri identified in this procedure that are unaffected by the reedwater 2 ; fire in this area.

Condensate 2

l l

l Circulating Water 5

l l

l l

Turbine Bypass System (TBS) 3,5 l

-l l

TBCCW I

5 l

l l

Rx Recirculation 5

l

~1 I

l

'l 1.

I I-1 I

ll l

l l

ll l.

I I

l l

~ cThis cystem has an independent power supply and does not require ensite or offsite power to operate.

NOTE la Safety function Leoend

. 1.

Reactivity Control 3.

Decay Heat Removal 5.

S@ porting Functions 2.

RC Maketq:

4.

Process Monitoring Page 3 of 13

' GPU Nuclxr APPEIOIX A Revision l'

. Oyst:r Creek Nuclur Genertting St: tion JUSTIFICATION FOR SCHEDULE RELIEF-TABLES

'l 1

FIK S/D SYSTEMS SUBJECT NOTE NOTE l

IITEM AKA/ZOE LOCATION PRESENT FIRE PROTECTION STATUS TO DEGRADATION 1

UNAFFECTED SYSTEMS 1

INTERIM EASURES I-I-

l

. l 4, 08-FA-6 480V Sugr. Existing detection and automat-Safety Systems-Onsite Safety Systems-Onsite Power

1. The existing detection..

.I l Room ically actuated total flooding Power l

l and automatic suppression l l

Halon 1301 systems will ex-l Rx Recirculation (Trip) l5 systems are considered l

l l

tinguish fire in its incipient Reactor Scram l1 Fire Water

  • l2,5l adequate to limit damage l

l

.I stage and minimize fire damage.

CRD Hydraulic l2 Service Water l5 I and protect the vulnerable i

'l Core Spray l2 Condensate Transfer 5

systems. ~ Therefore, in-l l

Containment Spray l5 RPV Level & Pressure (Local) 4 terin measures are not i

l Isolation Condenser 3

Reactor Scram (see text)

I required.

l l

IRM's (Electrical) 4 MS Isolation (Manually Close) 5 1

l-l.

'i Electrical 5 HIsolation Condenser (Manual 3

Drywell Cooling 5 1 control, one spurious l'

l l:

1 RBCCW 5

actuation closes one inboard l

1-l Main Steam (Out Iso.) '.5 condensate return valve) l l

EMRV/s (Control) 3 l

.I Shutdown Cooling 3

I I

4 l

Containment Moni-4 l '.

toring (Components l

and Electrical)

I I

ESW (Electrical) l.5 i

Clean Up System (Iso)l 5 l

l Rx Fuel Zone Level l4 I

I RPV Level & Pressure 4 ll l

(Electrical) l l

l 1

l l

l.

Non-Sofety Systems-l l

Offsite Power Feedwater (Cont Pwr) 2 l

l TBCCW (Control Pwr) 5 l

l lCire. Wtr. (Cont Pwr) 5 l

I; l

l.

l TBS (Electrical) 3,5 l

l l

l Condensate (Cire.

2 i

4 l

l Wtr. & TBCCW) l I

I 5.

08-FZ-8A' lE-Set combustible loading is low.

Safety Systeme-Onsitel ISafety Systeme-Onsite Power

.1. The existing area-wide l

l Room The area is presently.provided Power I

automatic suppression l

I with automatic wet pipe Containment Spray l5 system is considered

.l

~l sprinkler protection to Reactor Scram 1

ESW i5 l adequate to limit damage 1

i I

extinguish fires.

CRD Hydraulic 2

Rx Fuel Zone Level l4 l and protect the vulnerable ll l Isolation Cond.

113-Reactor Recirculation (Trip) 15 I systems. Therefore, in-1 1

l Core Spray (Iso Vive)l 2 Electrical l5 l terin measures are not

  • - l l

EMRV's 3 l Fire Water

  • 2,5 l required.

l l

IRM's 4 lCleang (Isolation) 5 l l

l MSIV's-5 lDrywell Cooling 5

l l

l' Shutdown Cooling 3 lRBCCW 5

l i

Service Water 5

l l

l l

l' l-H I

l l

l

  • This system has an independent power apply and does not require onsite or offsite power to operate.

NOTE la Safety Function Legend -

1.

Reacitivity Control 3.

Decay Heat Removal 5.

Supporting Functions

~

2.

RC Makeup 4.

Process Monitoring Page 4 of 13 i

1

,n.

CPU Nuclear APPEPOIX A Revirion 1

. Dyster Creek Nuclear Genercting Station JUSTIFICATION FOR SCHEDULE RELIEF TABLES I

l IIRL l

ll 1 5/D SYSILM5 5N JECT INUILJ lNUILI l

ITEM AREA / ZONE LOCATION PRESENT FIRE PROTECTION STATUS TO DECRADATION 1

UNAFFECTED SYSTEMS 1

INTERIM E ASURES I

l 6.

08-FZ-8C Battery Condensate 2

l (Cont'd)

Room (Electrical) l I ^

Tunnel.

TBS (Electrical) l5 l

ll Electric l'TBCCW (Electrical) l5 l

l l

Tray Room

! Circulating Water 15 l

l l

(Electrical) l l

I Rx Recirculation l5 l

l l

l l

l l

1

7. 108-FA-9 Office lCoeustible loading is low.

lEMRV's (2 EMRV's) l3 l Safety Systems-Onsite Power l

lThe reactor can be brought to l

l Building l Fire detection only. Detection l Shutdown Cooling 3 l l

l cold shutdown with the unaf-l l

l land manual hose capability l

IReactor Scram l1 Ifected onsite powered systems l l

combined with quick response by CRD Hydraulic 2

by utilizing the Emergency Op-l l

the fire brigade will assure Core Spray 2

erating Procedures as follows:I

! capability to achieve hot and l

l EMRV's 3

I cold shutdown.

Containment Spray 5

If any EMRV's are cycling, Emergency Service Water (ESW) 5 enter procedure EMG 3200.01, l

l Rx Recirculation 5

RC/P-1. If the entry condi-Electrical l5 tions for procedure EMG IRM's 14 3200.02, Containment Control Main Steam (Isolation) l5 lare satisfied, the operater Containment Monitoring l4 lshall follow SP/T, DW/T, and Rx Fuel Zone Level l4 ISP/L utilizing systems l

RPV Level and Pressure 14 l unaffected by the fire in l

Shutdown Cooling l3 this area.

l Cleanup (Isolation) l5 ll Drywell Cooling 5

'l l

. RBCCW 5

ll Fire Water

  • 2,5.I I

1 Service Water 5

Condensate Transfer 5

l l

Non-Safety System-Offsite Power l

l l

l l

ll Feedwater 2

l l

Condensate 2

l l

Circulating Water 5

l l

Turbine Bypass System (TBS) 3,5 I

I I

I""

l' I I

l l

1 l

l

\\

l l

ll 1

l l

1 l

1 l

I I

I I

I l

1 I

I I

l l

l l

l CThis cystem has an independent power supply and does not requiru onsite or offsite power to operate.

NOTE 1: Safety Function Legend -

1.

Reactivity Control 3.

Decay Heat Removal 5.

Supporting Functions 2.

RC Makeup 4.

Process Monitoring Page 6 of 13 l

l

GPU bclear-APPEWIX A Revirion 1

-Dyster Creek Nuclear Genertting St; tion

.XtSTIFICATION FOR SCKDULE RELIEF TABLES I

i tmL i

S/D SYSTEMS SUBJECT NOTE NOTE l

l ITEM AREA /ZO K 1 LOCATION PRESENT FIRE PROTECTION STATUS TO DECRADATION 1

UNAFFECTED SYSTEMS 1

INTERIM K ASURES l

1 I

I lL 08-FZ-8A lMG-Set Non-Safety System-RPV Level and Pressure 4

I (Cont'd)

IRoom Offaite Power Condensate Tranofer 5

l I'

l Reactor Scram (see text) 1 l

l l

l l

Rx Recirculation 5

Core Spray (Iso. Vivs.)(Manual)l 2 l l

l-l l

l (Valves)

Isolation Condenser (Manual) l3 l l

1 l

l l

l l

MSIV's (Menually close) 5 l l

l l

l l

l Containment Monitoring 4 l l

l 1

l-l l

l

'l

Non-Safety System-Offsite Power l

l' I

I l

I l

l l

l Feedwater l2 l

l l

l l

Condensate 12 l

I-l l

l l

l Circulating Water 5

l l

l l

l l

Turbine Bypass System (TBS) 3,5 l

l l

l

, TBCCW 5

1 I

I l

l 6. l08-FZ-8C

~l Battery Combustible loading is low.

Safety Systems-Onsite Safety Systems-Oneite Power

.1.

The existing oetection l

l l Room lExisting detection and

' Power I

and automatic suppression l

l l Tunnel, l automatically actuated total systems are considered I

l (Electric lflooding Halon 1301 systems will Restor Scram 1

Fire mater

  • I5 adequate to limit damage
l l

'l1 rey Room lextinguish fire in its incipient Isolation Condenser 3

Ik Fuel Zone Level

!4 and protect the vulnerable l

.l l

l-Istage and minimize fire damage.

CRD Hydraulic 2 lReactcr Scram (see text) l1 l systems. Tiserefore, in-l l

l

-l l

Core Spray 2 lRPV Level & Pressure (Local) l4 l terin measures are not l

l l

l l-

.l EMV's ll 3 l Isolation Condenser (Manual l3 l required.

l l

l Containment Spray

'5 l control, one spurious ll l

ESW 5 l actuation closes one inboard i

Electrical 5 l condensate return valve) l 1

l MSIV's 15 l l

l l

l IRM's 4 l l

l

'l l

Drywell Cooling 5 l l

l I

l'

. l l RBCCW I 5 l l

l l

l Clean Up (Iso. Vlvs.)l 5 l l

l 1

l l

Shutdown Cooling l3 l l

l l

l l

Condensate Transfer l5 l

l l

'l ll l

l l (Electrical) l l

l l

'l l

Service Water l5 i

'l I

(Electrical) l l

l RPV Level & Pressure 1 4 l'

l (Electrical) l

'l l

Containment Moni-l4 l

l l

l l

toring (Electrical) l l

l

,1 l

l l

1 l

l l

1 l

l Non-Safety Systems-I l

l l

l Offsite Power l

l l

l l

l l

l Feedwater l2 l

l l

(Electrical) l l

l

\\

I l

l

'l l

8This system has an independent power s@ ply auf does not require onsite or offsite power to operate.

NOTE 12 Safety Function Legend 1.

Reactivity Control 3

Decay Heat Removal 5

Supporting Forw H--

. ~.. -

. - -. - - ~ ~ -. -..

d' GPti Nuclear APPD OIX A Revicion 1 Oy:tcr Creek Nucl2cr Generating Stttion JUSTIFICATION FOR SCHEDULE RELIEF TABLES l

l FIRL

-- ll i, 5/D hThlLPD 5LBJtil lMulLI.

NUILI l

lITEMI AREA /ZOE LOCATION PRESENT FIRE PROTECTION STATUS TO DEGRADATION 1

UNAFFECTED SYSTEMS 1

INTERIM E ASURES I

I Monitoring l Existing detection will provide Combustible loading is low.

Safety Systeme-Onsite l Safety Systemo-Onsite Power

1. The existing detection 8.

FZ-10A

& Change I Power i

and automatic suppression Room Area l warning of fire in its incipient Reactor Scram I

systems are considered letage and automatic wet pipe Core Spray (Valves) 2 CRD Hydraulic 2-adequate to limit damage l

-l sprinkler system above and l Isolation Condenser l3 Containment Spray 5

and protect the vulnerable l

Ibelow the falso ceiling will IEMRV's l3 ESW 5

systems. Therefore, in-l l

l lextinguish a fire and minimize Rx Fuel Zone Level 4

Core Spray (Manual) 2 teria measures are not.

l l

l

.ldamage.

IRM's 4

MSIV's 5

required.

l

. l l

l' Shutdown Cooling 3

Electrical 5

l l

RPV Pressure & Level.

4.

Fire Water

  • 2,5 Drywell Cooling (Iso. Valves) 5 l

Clean up System 5

ll I

I
1 i

.l l

Conteinment Monitoring 4

l l

I l

RBCCW l5 l

l l

. Service Water-

'5 Condensate Transfer 5

j-RPV Level & Pressure (Local) 4 j

l Isolation Condeneer (Manuel 3

I control, local level l

l l

indication)

I'

.I I

I Non-Safety System-Offeite Power l

Feedwater 2

Condeneste 2

circulating Water 5

l

'I Turbine Bypass System (TBS) 3,5 l

l TBCCW 5

l i

Rx Recirculation 5 l l

1

,1 l

-l9.

18-FZ-118

' Turbine Although combustible loading is Safety Systeme-Oneite Safety Systems-Onsite Power l

The reactor can be brought to i

Building-high, it is confined to Turbine Power l

l hot shutdown with the unaf-

-l Lube Oil l011 equipment which is protected l l2 l Reactor Scram l1 lfected onsite powered systems I

.I l Storage, Iby automatically actuated delugelCore Spray 1

lEMRV's l3 lby utilizing the Emergency Op-l Pumping &

water spray systems. The l Condensate Transfer l5 l Fire Water

  • 12 5 lerating Procedures as follows:.

Pur. Areas bearing lift pump is provided IDrywell Cooling l5 IMSIV's l$I with a closed head sprinkler l Service Water i5 lRx Recirculation (Trip) l5 l Procedural Guidelines (EOPS) system and the trays in the arealRBCCW (SWS) l 5-lRPV Level & Pressure (Local) l4 l l

are protected by a closed head Shutdown Cooling 3

Isolation Condenser 3

1. Evaluate entry conditions I

automatic sprinkler system.

(RBCCW)

Containment Spray 5

of EMG 3200.01. If the l.

l l All these systems combined, will Containment Moni-4 Emergency Service Water 5

entry conditions are set-i i

-l l'

minimize the apread of fire toring Reactor Fuel Zone Level l4 l infied, follow procedure l

l l

beyond the oil storage areas IRM's i4 l EMG 3200.01 utilizing l

l.

lwhile protecting cable.

RPV Level & Pressure l4 l l

l l

CRD Hydraulic l2 l l

f.

,, l l

l l

l l

e

- *This cystem has an independent power supply and does not require oneite or offsite power to operate.

MDE.ls Safety Function Legend 1.

Reactivity Control J.

Decay Heat Removal 4

5 Supporting Functionn 4

. GPU Nucl'Ir APPEM)IX A Revition 1 Oyster Creek Nuclscr Generating Stttion JUSTIFICATION FOR SCHEDULE RELIEr TABLES 1 5/D bTbItJCi SUBJLLI INUILI lMUIL 1

I t int.

I li PRESENT FIRE PROTECTION STATUS l TO DEGRADATION 1

UNAFFECTED SYSTEMS 1

INTERIM W ASURES IITEMI AREA /20W l LOCATION I

I I

l 9,'lTB-FZ-11B I Turbine l

lNon-Safety Systems-systems unaffected by the l (Cont'd)

Building-Offsite Power fire in this zone. If

, Lube Oil I

the entry conditions are (Storage, Feedwater 2

not satisfied, follow Puging &

Condensate 2

normal shutdown procedures.l

.I Pur. Areas Circulating Water 5

l 1

-l l

TBCCW 5

2. Complete evaluatian of I

I l

TBS 3,5 entry conditione for EE.

l l

l 3200.02 Containment Con-l

.I trol cannot be determined l-because circuits and com-

^l ponents for torus water I

temperature and drywell I

temperature were not J

identified in the original l

Apperrfix R Fire Evaluation.

1 l

Since the other parameters, l

Torus water level and i

I l-I drywell pressure have been l

l considered and may be l

l l

affected by the fire in l,

I this zone, utilize systeme I identified in SP/T-2 and i

DW/T to assure Containment

~

t l

l Control.

l' 1

l l

l l

. NOTE:

A) Modifications to the Elec-I trical Power System prior l' I

i to startup will assure one train of the onsite elec-l ll trical power system which l 1

I will in turn render systemel l

l in the reactor building l

1 I

with power to operate.

l t,

l l

Because culd shutdown cannot

be achieved utilizing the E0Ps alone, CPUNC will either I

A. Post a continuous fire l

l watch.

l 1

I I

I l!

ll l

I I

I I

I l

1 l

l l

l l

} eThis rystem has an independent power supply and does not require onsite or offsite power to operate.

1.' Reactivity Control 3.

Decay Heat Removal 5.

Supporting Functions NOTE la Safety Function Looend 2.

RC Makeup 4.

Process Monitoring Page 8 of 13

GPU Nuclear APPDDIX A Revision 1 Dy;tte Creek Nucirr Genercting Stction JUSTIFICATION FOR SCHEDULE RELIEF TABLES l

r ut.

I 5/D SYSTEMS SLEJECT I mit' NOTE l

ITEM AREA / ZONE LOCATION PRESENT FIRE PROTECTION STATUS l in M M *f4TiuN 1

UNAFFECTED SYSTEMS 1

INTERIM EASURES l

'l 1-9.-

TB-FZ-11B Turbine B. Develop and implement a (Cont'd)

Building-suppleiaerotel procedure in I

Lube Oil l

addition to the E0Ps which 1-

Storage, I

provides the capability to Pumpinq &

achieve cold shutdown.

Pur. Areas C. Poet a continuous fire I

watch until the supplemen-

- l l

tal procedure is developed.

l l

110.- TB-FZ-11C l Turbine Fire detection only. Detection Safety Systems-Onsite Safety Systems-Onsite Power ~

IThe reactor can be brought to Building and manual hose capability Ewer hot shutdown with the unaf-l Switchgear cambined with quick response by Reactor Sceam 1

facted onsite powered systems

' Area l the fire brigade will assure lDrywell Cooling l5 EMtV's 3

by utilizing the Emergency Op,

Mezzanine capability to achieve hol and l Serv e Water l5 Fire Water

  • I5 ersting Procedures as follows l cold shutdown.

lCRD draulic l2 MSIV's l5 l

i2 Rx Recirculation (Trip) l5 l Procedural Guidelines (EOPS) l l

l Core Spray) l5 RPV Level & Pressure (Local) l4 l l

RBCCW (SWS

-l l

i Shutdown Cooling l3 Isolution Condenser l3

1. Evaluate entry conditions 1

l (RBCCW) l Condensate Transfer I5 of ENG 3200.01. If the Emergency Service Water 5

entry conditions are sat-Non-Safety Systems-Containment Spray 5

infied, follow procedure Offsite Power Cleanup (Iso. Valves) 5 EMG 3200.01 utilizing Rx Fuel Zone Level 4

systems unaffected by the l

l l

Feedwater l2 l Containment Monitoring l4 l fire in this zone. If l

l l

l Condensate i2 IRPV Level and Pressure 14 l the entry conditions are l

l Circulation Water 5

IRM's 4

not satisfied, follow l

l TBCCW (Electrical) 5 Electrical 5

normal shutdown procedures.l

- 1 I

l Non-Safety System-Offsite Power

2. Complete evaluation of l

l l

l entry conditions for EMG l

l Turbine Bypass System (TBS) 3,5 I 3200.02 Containment Con-l l

trol cannot be determined I

because circuits and com-i ponents for torus water temperature and drywell temperature were not identified in the original Appendix R Fire Evaluation.

Since the other parameters, Torus water level and drywell pressure have been considered and may be 1

1 affected by the fire in this zone, utilize systema l

l identified in SP/T-2 and DW/T to assure Containment Control.

l l

eThis cystem has an independent power supply and does not require onsite or offsite power to operate.

NOTE 1: Safety Function Legend -

1.

Reactivity Control 3.

Decay Heat Removal 5.

Supporting Functions 2.

RC Makeuo 4.

Process Monitoring Page 9 of 13 J

m

GPU Nuclear APPEM)IX A Rovirion 1 Oyster Creek Nuclxr Genercting Station JUSTIFICATI0id FOR SCHEDILE RELIEF TABLES 1

I FIRE l S/D SYSTEMS SUBJECT l'NOTEl NOTE l

lITEMI AK A/ZOK LOCATION PRESENT FIRE PRO 1ECTION STATUS TO DECRADATION 1

UNAFFECTED SYSTEMS 1

INTERIM K ASURES 1

1 i

i 110. lTB-FZ-IIC l Turbine l

NOTE:

l l

l(Cont'd)

IBuilding l

l l

lSwitchgear

! A) Modifications to the Elec-1

-l Aron trical Power Syntem prior IMerzanine to startty will assure one i

train of the onsite elec-l l

trical power system which ll will in turn render systems l

in the reactor building.

l with power to operate.

Because cold shutdown cannot be achieved utilizing the EDPs alone, GPUNC will eithers l

A. Post a continuous fire watch.

B. Develop and implersnt a I

supplemental procedure in l addition to the E0Ps which l l

l l

provides the capability to l I

l l

l achieve cold shutdown.

I watchuntilthesupplemen-l C. Post a continuous fire I

tal procedure is developed.

I I

i l

l 1

1 I

I I

ll l

1 l

l l

l l.

i l

i I

I I

1.

I i

I I

I SThis cy: tem has an independent power supply and does not require oresite or offsite power to operate.

POTE 12 Safety Function Legend -

1.

Reactivity Control 3.

Decay Heat Removal 5.

Supporting Functions 2.

RC Makeup 4.

Process Monitoring Page 10 of 13

GPU Nuclear APPE WIX A Revialon 1

.Dy-ter Creek Nuclz r Genertting Stttion JUSTIFICATION FOR SCHEDULE RELIEF TABLES FIRE S/D SYSTEMS SUBJECT INOTE NOTE l

ITEM AREA / ZONE LOCATION PRESENT FIRE PROTECTION STATUS TO DECRADATION lI UNAFFECTED SYSTEMS 1

INTERIM EASURES l

1 1

11.,lTB-FZ-11D Turbine Combw tible loading is low.

Safety Systems-Onsite Safety Systems-Onsite Power

1. The existing aree-wide

.I Building H Seal 011 Unit is protected Power automatic suppression sys-2 l

l South End by an automatic deluge water Reactor Scram 1

tem is considered adequate l

l Basement spray system. Area wide Core Spesy 2

EMRV's 3

to limite damage and pro-l automatic wet pipe sprinkler ESW 5

Fire Water

  • 2,5 tect the vulnerable sys-I protection is provided. These Electrical 5

MSIV's 5

tems. Therefore, interim systems will extinguish a fire Drywell Cooling 5

Rx Recirculation (Trip) 5 measures are not required.

and minimize damage.

Service Water 5

RPV Level & Pressure (Local) 4 l

Rx Fuel Zone Level 4

Isolation Condenser (Manual) 3 ll Isolation Condenser 3

l I

(Elect cical)

Ncn-Safety System-Offsite Power l

Condensate Transfer 5

I I

(Electrical) l ITurbine Bypass System (TBS) 3,5 l l

Containment Spray I5 l l

l (Electrical) l l

RBCCW (Electrical, 5 I I

I I

SWS)

I 1

CR0 Hydraulic 2

l l

(Electrical)

I l

IRP/ Level & Pressure 4

I l

l (Electrical) l I

I Containment Moni-4 l

1 I

toring (Electrical)

I' l

I IRM's (Electrical) 4 l

l Shutdown Cooling 3

1 ll l

l (Electrical) l Clean Up (Isolation) 5 I

I

%n-Safety Systems-Offsite Power l

l l

1 i

Feedwater 2

l Condensate 2

1 Circulating Water 5

I TBCCW 5

l 1

1 1,

.1 1

I I

I l

i I

i 1

I l

.1

- l I

l l

l l

l l

l l

l 1

L I

I I

I cThio system has an independent power supply and does not require onsite or offsite power to operate.

NOTE 1. Safety Function Legend -

1.

Reactivity Control 3.

Decay Heat Removal 5.

Supporting Functions 2.

RC Makeup 4.

Process Monitoring Page 11 of 13

GPU Nuc1:rr APPEleIX A Revirion 1 Oyst:r Creek Nucle r Genersting Stction JUSTIFICATION FOR SCHEDULE RELIEF TABLES I.

FIRE S/D SYSTEMS SUBJECT NOTE NOTE l ITEM AREA /ZDE LOCATION PRESENT FIRE PROTECTI0it STATUS TO DECRADATION 1

UNAFFECTED SYSTEMS 1

INTERIM MEASURES I

12.

TB-FZ-11E Turbine Combustible loading is li.w.

Safety Systems-Onsita' Safety Systems-Onsite Power

1. The existing automatic Building The overall area is protected Power I

suppression systems are Reactor Scram 1

considered adequate to Condenser by an automatic wet pipe Bey sprinkler system including the Core Spray 2

Fire Water

  • 2,5 limit damage and protect l

cable trays. This system will Condensate Transfer 5 lMSIV's (5 l the vulnerable ayatems.

l l

extinguish a fire and minimize Rx Fuel Zone Level 4 lRx Recirculation (Trip) 15 i Therefore, interim measureal-damage.

Drywell Cooling 5

Isolation Condenser 3

are not required.

rvice Water 5

IRM's 4

lRBCCW (SWS) 5 Containment Monitoring i4 l l

l Clean Up (Icolation) 5 RPV Level and Pressure 14 l l

Electrical 5

Non-Safety Systems-CRD Hydraulic 2

orreite Power ESW 5

Containment Spray 5

l l

Feedwater 2

EMRV's 3

i l

Condensate 2

I Circulating Water 5

J

'TBCCW

  • 5 l

l TBS 3,5 l l

1 l

I l

g

+

I I

l I

I I

I

.I i

l l

l l

I I

l I

11 I

I I

i

'l I

l I

l 1.

l l

I l

l l

1 l

l 1

CThis cystem has an independent power supply and does not require onsite or offsite power to operate.

NOTE 1: Safety function Leoend -

1.

Reactivity Control 3.

Decay Heat Removal 5.

Supporting Functions 2.

RC Makeup 4.

Process Monitoring Page 12 of 13

d GPU Nuclear-APPEPOIX A Revision 1 Oyster Creek Nuclear Gener' ting Stction JUSTIFICATION FOR SCHEDULE RELIEF TABLES FIRE S/D SYSTEMS SUBJECT NOIE NOTE ITEM AREA /ZOK LOCATION PRESENT FIRE PROTECTION STATUS TO DECRADATION 1

UNAFFECTED SYSTEMS 1

INTERIM E ASURES 13 CW-FA-14 Circulet-This area is not enclosed.

Safety Systems-Onsite Safety Systems-Onsite Power This area is continuously ing Water Combustible loading is low.

Power manned and monitored by

. l IIntake Should a fire occur by the IReactor Scram I

security guards located at

.I transformers, oil will be ESW 5 lEMRV's 3

the intake structure. In retained by the dikes Electrical 5

CRD Hydraulic 2

addition, the area is pro-surrounding them.

Service Water 5

IRM's 4

vided with 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> video RBCCW (SWS) 5 MSIV's 5

surveillance by plant Containment Spray 5

Fire Water

  • 2,5 security.

(ESW)

Rx Fuel Zone Level 4

1-Condensate Transfer 5

Isolation Condenser 3

l (ElectricaM Core Spray 2

i Drywell Cou11ng 5

Cleanup (Isolation) 5 l (RBCCW) l Containment Monitoring 4

ll Shutdown Cooling

'l3 RPV Level and Pressure 4 l l

l (RBCCW) l l

l l

.Non-Safety System-Offsite Power l

l 1

Non-Safety Systems-8 l

l orrsite Power Turbine Bypass System (TBS) 3,5l l

Feedwater (CWS) 2

'l Condensate (CWS) 2 Circulating Water 5

TBCCW (CWS) 5 I

I Rx Recirculation 5

1; I (TBCCW)

I I

I l

l I

I I

i l

I-1:

I I

l 1

1

.I I

l 1

I I

i 1

1 l

I I

1 I

l I

l 1

1 I

I I

l

'l l

ll l

CThiu system has an' independent power s@ ply and does not require onsite or offsite power to operate.

NOTE 1: Safety Function Legend -

1.

Reactivity Contrcl 3.

Decay Heat Removal 5.

Supporting Functions 2.

RC Make@

4.

Process Monitoring Page 13 of 13

. = -

APPENDIX B P:ga 1.

SUMMARY

OF EVALUATION AND EXEMPTION REQUESTS FIRE AREA /

APP. R'NON-MOD.*

FIRE TECHNICAL EXEMPTIONS ZONE LOCATION ELEVATION COMPLIANCE REQ.

LOADING REQUESTED lhFZ-1A Reactor Bldg.

119 No No NR 1-FZ-1B Reactor Bldg.

95 No-Yes Low NR l

l 1-FZ-1C Reactor Bldg.

75 No Yes Low NR

'1-FZ-ID

-Reactor Bldg.

51 Yes Yes Low Propose converting existing del. sys. to manual actuation.

After mod's complete.

Request exemption from additional suppression' and detection.***

1-FZ-1E Reactor Bldg.

23 Yes Yes.

Low Propose converting existing del. sys, to manual actuation.

After mod's complete.

Request exemption from additional suppression and detection.***

5 1-FZ-1F Reactor Bldg.'

-19 No No NR

-- FZ-1G Reactor Bldg.

38 & 51 No No

.N R 3

'FA-2 Reactor Bldg./

No No NR Drywell

.FA-3A Turbine' Bldg.

Mezzanine Yes**

Yes High NR 4160V Swgr. 1C

l APPENDIX B (Continutd from Pege 1.)

Pcg2 2.

SUMMARY

OF EVALUATION AND EXEMPTION REQUESTS FIRE AREA /

APP. R NON-MOD.*

FIRE TECHNICAL EXEMPTIONS-ZONE LOCATION ELEVATION COMPLIANCE REQ.

LOADING REQUESTED FA-38 Turbine Bldg.

Mezzanine No No NR 4160V Swgr. ID FA Cable Spreading 36 Yes No Covered by alt.

Room shutdown facility

  • (1) Cable rerouting or (2) one hour fire barriers (three hour where noted) c2 Although systems identified here are in non-compliance, redundant systems located in other fire areas / zones, which ccnnot be damaged by a fire here will assure safe shutdown.
      • Modifications involving circuit rerouting within this zone may not fall under sphere of influence of existing ceppression systems which protects cable trays only. An exemption from additional suppression and detection will be requested.

APPENDIX B Prgs 3.

FIRE AREA /

APP. R NON-MOD.*

FIRE EXEMPTION >

ZONE IDCATION ELEVATION COMPLIANCE REQ.

LOADING REQUESTED FA-5

-Control. Room 46 Yes No Covered by' alt.

shutdown facility.

FA-6 480V-Swgr. Room 23'-6" Yes Yes thr.

N R*

To be split into two (2) i separate fire areas.

FA-7 Redefined l

8-FZ-8A MG Set Room 35' Yes Yes Low Fire detection system.

'8-FZ-8B Mech. Equip. Room 23'-6" No No NR i

8-FZ-8C Battery Room 35' Yes Yes Low NR Tunnel-Elec.

Tray Room

-FA-9 Office Bldg.

All Yes Yes Automatic Suppression 10-FZ-10A Monitoring &

46' Yes Yes Low.

One hour barriers on valve circuits l

Change Room Area

.10-FZ-10B Chem. Lab-Laundry 35'-

No Yes Automatic Suppression

& Inst. Shop 10-FZ-10C Incorporated into 10-FZ-10A 11-FZ-11A Turbine Bldg..

46' No' No NR Operating Fir.

11-FZ-115 Turbine Bldg.

Yes Yes-High NR (3 hr. banier) -

i..c(1) Cable' rerouting or (2).'one hour fire barriers (three hour where noted) j

-.=

~

APPENDIX B Pega 4.

FIRE AREA /

APP. R NON-MOD.*

FIRE

. EXEMPTION ZONE

_ LOCATION ELEVATION COMPLIANCE REQ.

LOADING REQUESTED 11-FZ-11C

' Turbine Bldg.

Mezzanine Yes Yes High NR Swgr. Room (3 hr. barrier) 11-FZ-11D Turbine Bldg.-

Basement Yes Yes Low Fire detection South End system.

11-FZ-11E Turbine Bldg.

Mezzanine &

Yes Yes Low Fire detection system.

Basement 20 ft. Separation with no interviewing com-bustiables.

11-FZ-11F Turbine Bldg.

Basement No Yes NR 1-FZ-11C Turbine Bldg.

Mezzanine No No NR South End 11-FZ-11H Turbine Bldg.

No No NR Southeast End FA-12 Main XFMR &

Yard No No NR Cond.

FA-13 Aux. Boiler Yard No No.

NR House FA-14' Circulating Yard Yes Yes Fire detection Water Intane system & suppression system. Also request exemption from fire barrier separation of transformers.

Struc-ture is outdoors.

  • (1) Cable rerouting or l

(2) one hour fire barriers (three hour where noted)

{

APPENDIX B Pcg2 5.

FIRE AREA /

APP. R NON-MOD.*

FIRE EXEMPTION ZONE IDCATION ELEVATION COMPLIANCE REQ.

LOADING REQUESTED FA-15 No. 1 Emer.

Yard No No NR Dies. Gen. Rs.

FA-16 Emer. Dies. Gen.

Yard No**

Yes NR Fuel Stcrage FA-17 No. 2 Emer. Dies.

No No NR Gen. Room FA-18 Diesel Fire Water Yard No No NR Pump House FA-19 Old Radwaste All No No NR Bldg.

FA-20 New Radwaste All No No NR Bldg.

FA-21 Aux. Off Gas All No No NR Bldg.

FA-22 Mech. Equip.

63' No No Undet.

NR until des.

complete FA-23 New' Warehouse All No No NR FA-24 Maintenance All No No NR Bldg.

G(1) Cable rerouting or (2) one hour fire barriers (three hour where noted)

'** Modifications to allow fuel supply to either gen.

in the event of fire in this room are required.

4

APPENDIX B Pcgs 6..

s FIRE AREA /

APP. R NON-MOD.*

FIRE EXEMPTION ZONE LOCATION ELEVATION COMPLIANCE REQ.

IDADING REQUESTED FA-25 New Fire Pump Yard.

No No NR House & Tk.

FA-26 Turbine Bldg.

Mezzanine No No NR Battery Room o

l c(1) Cable rerouting or

.(2) one hour fire barriers (three hour where noted)

.~

APPENDIX C Page 1.

OYSTER CREEK STATION F

TENTATIVE NON-REGULATORY INITIATED MODS. DURING CYCLE 11 ('85) OUTAGE S. No Title Man Hours 1.

Torus Water Drain Line to TWST 240 2.

Control Room Human Factors Mods - Phase 3 4,500 l

3.

A&B 125V DC System Breakers Open Ind.

1,500 i

4.

Iso Condenser Pipe Break Monitor 7,500 Excess Flow Check Valve 7,500 5.

6..

ESW Rad Monitor 1,200 a

7.

RBCCW Circuit Mod 2,700 E

8.

Screen Wash Sluice Line 9,000 i

~

9.

Additional Spent Fuel Storage - Poison Racks 67,500 10.

Core Spray Fill Pump Circuit Mod.

1,050 11.

Diesel. Generator Trip Logic Mod.

1,800 12.

Intake Evaluation & Upgrade 6,750

-13.

Primary Containment Temp Monitor

'30,000 2

1 14.

Maintenance Platforms 4,500 15.

Core' Spray System Increased Flow 3,600 16.

Chlorination System Upgrade 3,900

'17.

RBCCW Hx Retubing 19,500 18.

Intake Conduit Replacement 6,750 19.

. Reroute RWCU Return Line to FW Sys.

9,600 20.

Modify Vacuum Priming System--

2,400 21.

. Upgrade Pump Room HVAC 13,500-

APPENDIX C Page 2.

OYSTER CREEK STATION TENTATIVE NON-REGULATORY INITIATED MODS. DURING CYCLE 11 ('85) OUTAGE S. No.

Title Man Hours 22.

Additional DG Fuel Storage Tank 2,100 23.

Control DC Power for 34 & 230 KU Bkrs.

4,200 24.

RWCU System Main Pumps Upgrade 6,000 25.

Condensate Demineralizers Upgrade 4,500 TOTAL =

221,790 Total No. of Items = 25 t

'm

APPENDIX C Page 3.

OYSTER CREEK STATION TENTATIVE REGULATORY INITIATED MODS. DURING CYCLE 11 ('85) OUTAGE S. No.

Title Man Hours 1.

SEP Environ. Qual. Safety Related Elec. Equip.

12,000 2.

ECCS System Improvement Mods - Sparger 510,000 3.

Plant Computer & Emergency Response Facility 10,500 Data System 4.

Containment Vent & Purge System Upgrade 45,000 5.

Rx Protection Motor Generator Sets 1.1 & 1.2 1,500 6.

125 VDC System Upgrade Phase 3 3,000 7.

Appendix R Modifications 177,000

)

8.

RCS Vent on Isolation Condenser 19,500 9.

Rx Protection System Analog Upgrade 30,000 10.

Anchor & Supt. of Safety Rel. Elec. Equip. (SEP) 60,000 11.

Cont. High Range Radiation Monitor 3,600 12.

Recire. Valves Interlock Mod.

3,600 13.

Radiation Signals Purge & Vent Valves 2,100 14.

NUREG 0696 Emergency Resp./NSE Facilities 21,000 15.

SEP Required Mods / General 87.000 985,800 1

TOTAL

=

GRAND TOTAL 1,207,500 l

FOR ALL MODS

=

Total No. of Items = 15

>