ML20133G706
| ML20133G706 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 10/09/1985 |
| From: | Fiedler P GENERAL PUBLIC UTILITIES CORP. |
| To: | Zwolinski J Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8510160091 | |
| Download: ML20133G706 (8) | |
Text
a GPU Nuclear Corporation Nuclear
- =g;388 Forked River NewJersey08731-0388 609 971-4000 Writer's Direct Dial Number:
October 9, 1985 Mr. John Zwolinski, Chief Operating Reactor Branch No. 5 Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Zwolinski:
Subject:
GPU Nuclear Corporation (GPUN)
Oyster Creek Nuclear Generating Station Docket No. 50-219 Fire Proteccion The NRC staff is currently reviewing the Oyster Creek " Fire Hazards Analysis and Appendix R Section III.G Safe Shutdown Evaluation", which was submitted by letter dated April 3,1985. The staff contacted GPUN by telephone to identify those areas of the submittal which involve staff concerns and questions which require resolution prior to completion of the staff's Safety Evaluation Report (SER). After a number of discussions by telephone, GPUN and the staff have reached agreement on the resolution of these concerns.
Currently, GPUN is revising, on a page replacement basis, the April 3, 1985 submittal to incorporate the agreements reached; however, in order to expedite the review process, Enclosure 1 provides a summary description of the agreements reached and the resultant changes in the submittal. This information provides the basis for the staff to complete their SER while the revisions to the submittal are being prepared.
The projected schedule for submittal of the revised pages is November 30, 1985.
Should you have any questions please contact Mr. Michael Laggart of the GPUN BWR - Licensing Department at (201)299-2341.
Very truly yours, 1
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Vice President & Director
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GPU Nuclear Corporation is a subsidiary of the General Pubhc Utihties Corporation
. cc: Jack N. Donohew, Jr.
U.S. Nuclear Regulatory Comission 7920 Norfolk Avenue, Phillips Bldg.
Bethesda, MD 20014 Mail Stop No. 314 Dr. Thomas E. Murley, Administrator Region I I
U.S. Nuclear Regulatory Comission 631 Park Avenue King of Prussia, PA 19406 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731 i
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Staff Concern:
In numerous sections of the submittal, the statement is made that cables will be rerouted or protected with fire barriers. These sections should specify the option to be implemented.
Resolution:
The options specified, reroute or protect with fire barriers, are both acceptable in meeting the requirements of Appendix R.
An option is specified since detailed engineering and installation plans are in development. Other considerations in continuing reviews may require changes in the selected protection method. Where possible, applicable sections of the submittal will be revised to specify the option to be implemented; however, since both methods are i
acceptable, installation considerations may necessitate a change in the actual method implemented. The Appendix R submittal is maintained as a reference document for the Appendix R work and is updated on a continuous basis to reflect the actual plant configuration as modifications are completed.
Staff Concern:
The submittal identified fire detection and suppression systems provided in various fire areas; however, the information provided does not indicate i
where these systems are area wide or partial area protection.
Resolution:
The submittal will be revised as necessary to clearly identify the extent of coverage for fire detection and suppression systems. Table 1 provides a listing of fire detection / suppression systems and specifies the degree of protection.
Staff Concern:
The exemption requests do not specify the section of Appendix R for which execption is being requested.
Resolution:
The submittal will be revised to clearly indicate the applicable section of Appendix R for which exemption is requested. All requested exemptions are from the requirements of Appendix R Section III.G.2 with the exception of Fire Zones TB-FZ-llD and TB-FZ-llE. The requested exemption in TB-FZ-llD is from the requirements of Section III.G.2 and III.G.3; and the exemption in TB-FZ-ilE is from the requirements of Section III.G.3. Additionally, the exemption requested for Fire Zone 08-FZ-8A (fire detection i
system) and for Fire area CW-FA-14 (Detection /
Suppression) will be withdrawn.
Staff Concern:
Manual actions are required within 45 minutes for postulated fires in numerous locations. Credit can not be taken for manual actions, within the affected fire area, in less than I hour.
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PAGE 2 0F 4 Resolution:
The manual actions referred to are accomplished at locations outside the Fire Zone involved in the fire.
The submittal will be revised to clearly indicate tnat manual actions are accomplished in locations independent of the Fire Zone under consideration.
Staff Concern:
Two cable pull pits are identified in the submittal for which it is proposed to seal tne cover plate.
In addition to sealing the cover plate, fire detection capability snould be provided and the seal should be surveilled in accordance with the Technical Specification for fire barriers.
I Resolution:
The cable pull pits in question will be filled with sand or fire resistant material which eliminates the concern.
In the event that filling these pits proves impracticable, three hour fire barriers will be installed. The submittal will be revised to describe the protection being provided.
Staff Concern:
The submittal does not discuss fire area boundaries.
Verify that fire area boundaries are of rated construction.
Resolution:
Fire area boundaries are identified in tne Fire Hazards Analysis and were approved in the NRC SER issued after review of the Oyster Creek Fire Protection Program - Comparison to BTP 9.5.1".
These boundaries are of ratable construction including doors, dampers, and penetration seals as accepted in the BTP 9.5.1, Appendix A review and associated NRC SER. The submittal will be revised to include this position.
Staff Concern:
Many of the zone boundaries appear to be unacceptable for providing adequate separation of shutdown systems. Zone boundaries which separate redundant shutdown systems should be continuous with fully sealed or protected openings.
Boundaries snould be surveilled in accordance with the applicable Technical Specifications.
Resolution:
Fire Zones at the Oyster Creek station are logical divisions of fire areas based on existing walled construction within the area even though openings through the boundary may exist.
These boundaries were utilized in the Appendix R safe shutdown evaluation to demonstrate separation of safe shutdown equipment and circuits. Safe shutdown is accomplished using defined safe shutdown paths which are independent of or protected through the zone in wnich the fire is postulated.
PAGE 3 0F 4 Fire zone boundaries which contain unprotected openings through which fire propagation could affect the designated shutdown path for the zone under consideration will be modified to meet the following criteria:
A.
All penetrations will be sealed or protected with automatic suppression (area wide or water spray) except as provided in B below.
B.
Penetration sealing or protection is not required where there exists in the adjacent zone a minimum physical separation of 50 feet horizontal distance between the penetration and any cable or equipment forming the availaDie shutdown patn for the zone under consideration.
C.
Penetrations will be surveilled in accordance witn the Technical Specifications. GPUN will request changes to the existing Technical Specifications to allow surveillance on a statistical basis in accordance with the Standard Te:hnical Specifications.
The submittal will be revised to include this criteria and identify the required modifications.
Additional clarifications will be included to clearly identify the sealing material and minimum thickness. Where penetrations are sealed with RTV silicone foam a minimum thickness of 6 inches will be provided.
Staff Concern:
In Fire Zones OB-FZ-228 and 08-FZ-22C the entry portals provide common access to both zones.
Verify that in the event of a fire in one zone, safe shutdown Can be Accomplished independent of the other zone.
Resolution:
In the event of a fire in either cable bridge tunnel (08-FZ-228 or 08-FZ-22C), safe shutdown is accomplished utilizing the remote shutdown capability which is independent of the cable bridge tunnels. The submittal will be ' revised to include this infcrmation.
Staff Concern:
The justification for the exemption requested f n fire zone RB-FZ-lF refers to a deluge system in this zone which appears to be an error.
Resolution:
There is no deluge system in fire zone RB-FZ-lF. The submittal will be corrected.
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PAGE 4 0F 4 Staff Concern:
The statement "...the fact that the safe shutdown path selected for this zone is not impacted by interaction (due to fire) between the penetration openings and any selected safe shutdown path circuitry contained in the adjacent areas provides reasonable assurance that fire will not propagate from one side of the boundary to the other". is not clear.
Verify that fire propagation through the boundry will not effect safe shutdown.
Resolution:
This statement in the applicable sections will be revised to state that fire propagation through the boundry will not affect safe shutdown; or the boundry wil! De justified in accordance with the criteria discussed above for zone boundries separating equipment and cables associated with the defined shutdown path.
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TABLE 1 1
FIRE DETECTION / SUPPRESSION SYSTEMS BY FIRE ZONE (Note 1)
(Note 1) f Fire Zone Fire Detection System Fire Suppression System RB-FZ-1B Area wide ionization None RB-FZ-lC Area wide ionization - except Partial wet pipe sprinkler minor areas (Col R5 to R7/RA to over spent fuel cooling RB and Col RD to RF/R1 to R2) pumps i
RB-FZ-10 Area wide ionization -
Partial deluge - cable except minor areas (Col R1 to tray coverage R2/RE to RF and Col R1 to R2/
RC to Rd)
RB-FZ-lE Area wide ionization Partial deluge - cable tray coverage i
TB-FA-3A Area wide ionication Manual C0 Total Flooding TB-FA-3B Area wide ionization Manual C0 Total Flooding TB-FZ-llB Partial area coverage - Thermal Partial - deluge on A&B detectors on A&B Lube Oil Tanks lube Oil Tanks.
j Cable tray coverage
( Sprinklers) - Both levels.
1 TB-FZ-llc Area wide ionization None TB-FZ-llD done Area wide sprinklers j
TB-FZ-llE None Area wide sprinklers except east of column F I
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Fire Zone Fire Detection System Fire Suppression System OB-FA-6 Area wide ionization Halon - total flooding except hallway.
OB-FZ-BA None Area wide wet pipe sprink-1 lers except south of column R1 OB-FZ-8C Area wide ionization Halon - total flooding i
OB-FA-9 Partial ionization - Hallways None OB-FZ-10A Partial ionization Partial wet pipe sprink-
.lers above and below j
suspended ceiling in 4
monitor and change room and above ceilling in computer hallway. Addi-tional heads in Cable tray closet.
1 OB-FZ-10B Area wide ionization None OB-FZ-22A Area wide ionization Area wide wet pipe sprinklers j
OB-FZ-22B Area wide ionization Manual pre-action sprinklers. Area wide 08-FZ-22C Area wide ionization Manual pre-action sprinklers. Area wide.
NOTE 1:
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" Area wide refers to the area contained within the boundries of the fire zone".
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