ML13309B382

Forwards Updated Fire Hazards Analysis,Vols 1-4

ML13309B382
Person / Time
Site:	San Onofre
Issue date:	03/19/1984
From:	Baskin K Southern California Edison Co
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML13309B383	List: ML13309B382 ML13311A719
References
TAC-64883 NUDOCS 8403220018
Download: ML13309B382 (11)

Text

REGULAT@ *FORMATION DISTRIBUTIO Y

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ACCESON NBR:8403220018 DQCDATE: 84/03/19 NOTARIZED: YES DOCKET #

50"361 San Onofre Nuclear Station, Unit 2, Southern Californ 05000361 50-362 San Onofre ivclear Station, Unit 3, Southern Californ 05000362 AUTHNAME AUTHOR AFFILIATION BASKINK,P.

Southern California Edison Co.

RECIPNAME RECIPIENT AFFILIATION DENTONH.R, Office of Nuclear Reactor Regulation, Director

SUBJECT:

Forwards."Updated Fire Hazards AnalysisVols 14.

DISTRIBUTION CODE: B0028 COPIES RECEIVED:LTR, ENCLI. SIiE

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F Southern California Edison Company P. 0. BOX 800 2244 WALNUT GROVE AVENUE KENNETH P. BASKIN ROSEMEAD, CALIFORNIA 91770 TELEPHONE VICE PRESIDENT March 19, 1984 818-572-1401 Mr. H. R. Denton Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:

Subject:

FHA Update Consistent with 10 CFR 50.71(e)

Docket Nos.

50-361 and 50-362 San Onofre Nuclear Generating Station Units 2 and 3 Reference is made to the letter dated February 10, 1984 from Southern California Edison Company (SCE) to the Nuclear Regulatory Commission (NRC).

That letter transmitted thirteen (13) copies of the Updated Final Safety Analysis Report (Updated FSAR) for San Onofre Nuclear Generating Station, Units 2 and 3 (SONGS 2 and 3) in accordance with the requirements of 10 CFR 50.71(e).

As stated in the reference letter, the Updated Fire Hazards Analysis (Updated FHA) was to be transmitted to the NRC by separate letter.

SCE's letter to the NRC dated February 15, 1984 indicated that the Updated FHA would be submitted by March 16, 1984. Accordingly, enclosed are one signed original and 12 additional copies of the Updated FHA for SONGS 2 and 3.

The Updated FHA has been reformatted to provide more detail and clarity to the document than was included in the current FHA. Examples of new information provided in the Updated FHA are the addition of fire hazards analysis matrices for each fire area and zone and the addition of fire area features drawings, emergency lighting drawings and Technical Specification barrier drawings.

The results of this Updated FHA may be summarized as follows:

o The Updated FHA provides a total revalidation of the SONGS 2 and 3 fire protection program.

o The Updated FHA includes a Design Basis Table (Appendix D) that provides a direct and detailed comparison of the SONGS 2 and 3 fire protection program to the specific requirements of NRC Branch Technical Position (BTP) 9.5-1 (1977), Appendix A and 10 CFR 50, Appendix R, Sections III.G, 3 and 0.

o The BTP 9.5-1, Appendix A Design Basis Table clearly documents SONGS 2 and 3 compliance to the requirements and provides justification for any exceptions or alternative compliance noted.

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March 19, 1984 o

Previous commitments have not been changed in the Updated FHA with the exception of a few instances that are noted with justification provided in the Design Basis Table (BTP 9.5-1, Appendix A).

Most of these instances involve deviations from NFPA codes. In such instances, equivalent fire protection has been provided in accordance with good engineering Judgment.

o The 10 CFR 50.Appendix R Design Basis Table identifies specific deviations from the literal requirements of Sections III.G, J and 0 of Appendix R. Deviations identified, that have already been accepted by the NRC in previous licensing documents, are included in the tabulation along with deviations that have not been specifically identified previously and require NRC concurrence. A deviation request justifying the latter deviations is provided as Enclosure 1 to this letter and NRC approval of these deviations is hereby requested. In addition, those deviations that have been accepted previously by the NRC are tabulated in Enclosure 2 to this letter.

o Notwithstanding the above request, SCE believes that the NRC was informed and knowledgable during the licensing process for those areas of the SONGS 2 and 3 fire protection program that are not in literal compliance with current NRC requirements and that SCE's commitments were acceptable to the NRC as providing equivalent fire protection for those areas.

o The Updated FHA does not alter any conclusions drawn in the current FHA regarding the plant's capability for safe shutdown and cooldown in the event of a fire.

As a result of the intensive program conducted by SCE in the preparation of the Updated FHA, a number of changes to the SONGS 2 and 3 Operating License conditions and Technical Specifications have been identified. Accordingly, concurrent with this transmittal of the Updated FHA, proposed changes to the operating licenses and technical specifications are being submitted by SCE under separate cover for NRC review and approval.

Until NRC approval of the proposed changes is obtained, SCE recognizes that the current FHA as referenced in the operating licenses establishes the fire protection provisions for SONGS 2 and 3.

SCE is cognizant of the latest guidance provided by the NRC regarding implementation of requirements of 10 CFR 50, Appendix R. The submittal of the Updated FHA and proposed license and technical specification changes represents a significant effort by SCE to ensure that the fire protection program for SONGS 2 and 3 satisfies the NRC requirements. SCE recognizes that a timely review of the proposed license and technical

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Mr. H.

March 19, 1984

.sE specification changes in conjunction with the Updated FHA will require substantial NRC effort and SCE is prepared to provide assistance to the NRC as requested to facilitate review and approval.

If you have any questions regarding this matter, please call me.

Very truly yours, Enclosures cc: Mr. H. Rood, Project Manager (w/o encl)

Licensing Branch 3

3. B. Martin (w/encl)

Region V Administrator A. E. Chaffee (w/encl)

NRC Site Inspector

BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA

)

EDISON COMPANY, ET AL. for a Class 103 )

Docket No. 50-361 Unit 2 License to Acquire, Possess, and Use

)

UPDATED FHA Two Utilization Facilities and Related )

Licenses in Connection with Units No.

)

Docket No. 50-362 Unit 3 2 and 3 of the San Onofre Nuclear

)

UPDATED FHA Generating Station

)

SOUTHERN CALIFORNIA EDISON COMPANY, ET AL. hereby submit the Updated Fire Hazards Analysis (FHA) for San Onofre Nuclear Generating Station, Units 2 and 3 that has been updated consistent with the requirements of 10 CFR 50.71(e).

This update provides a revision to the original FHA (up to and including Amendment Number 13) and includes additional information which amplifies, clarifies, or updates the original text. This update also removes amendment numbers from the text and corresponding margin change bars and repaginates pages. The information contained in the responses to NRC questions is incorporated into the body of the Updated FHA. This submittal fulfills the requirements of 10 CFR 50.71(e) for both San Onofre Unit 2 and Unit 3 and reflects all changes up to a maximum of 6 months prior to the date of this filing.

The information included in this update supersedes and replaces the previously issued FHA information.

DLC:0639F

00@0 Subscribed on this day of ___a_____,

1984.

Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY By:

Kenneth P. Baskin Vice President Subscribed and sworn to before me this day of 22ZAze6 /5'

/ V Not y Public in and for the County of Los Angeles, State of California My Commission Expires:

J

/7&

Charles R. Kocher OFFICIAL SEAL James A. Beoletto AGNES CRABTREE Attorneys for Southern NOTARY PUBUC - CALFORNIA California Edison Company PRINCIPAL UFFICE IN LOS ANGELES COUNTY My Commission Expires Aug. 27, 1986 By:

Jam A. Beoo

SAN DIEGO GAS & ELECTRIC COMPANY By: 664 David R. Pigott Samuel B. Casey Orrick, Herrington & Sutcliffe Attorneys for San Diego Gas & Electric Company By:

Subscr ed and sworn to before me this day of/8 OFFICIAL SEAL LORAINE E. GRAY NOTARY PUBLIC -CALIFORNIj l

PRINCIPAL OFFICE IN ary Public in and fdr the City SAN DIEGO COUNTY and County of San Diego, Ca ifornia My Commission Exp. April 6, 1986

THE CIFY OF ANAHEIM By: 9 GORDON W. HOYT by DALE POHLMAN Alan R. Watts Rourke & Woodruff Attorneys for the City of Anaheim By:

Subscribed and sworn to before me this

( T/v day of f

Notary Pliblic in and fdr the County of Orange, State of California OFFICIAL SEAL E LUCILtE MOSES NOTARY PUBLIC - CALIFORNIA M

COUNT My comm. exies JNI 16, 1987

THE CITY OF RIVERSIDE By:

FRED KRAY Alan R. Watts Rourke & Woodruff Attorneys for the City of Riverside By:

Subscribed and sworn to before me this 7th day of

February, 1984.

Notary Public in and for the County of Riverside State of California OFFICIAL SEAL MARGARET 1. ALLEN NOTARY PUBLIC RIVERSIDE CO., CALIF.

My commission expires 4-29.87

Introduction to Enclosures 1 and 2 During the update of the San Onofre Nuclear Generating Station, Units 2 and 3 Fire Hazards Analysis, a systematic review of the fire protection program was conducted. In an attempt to insure compliance with license conditions and NRC fire protection requirements, SCE took advantage of participation in the Nuclear Industry Fire Protection Seminar held February 13 and 14, 1984 in Washington, D.C. In addition, recent NRC guidance provided by Generic Letter 83-33 and IE Information Notice No. 84-09 was carefully reviewed.

As a consequence of this process, deviations to 10 CFR 50, Appendix R were found, which had not previously been identified and accepted by the NRC. These deviation rdquests are detailed in Enclosure 1. In each case, a statement of the issue and a technical basis to support the deviation request-is provided.

In addition, Enclosure 2 identifies those deviations to NRC fire protection requirements that have been approved by the NRC and documented in the Safety Evaluation Related to the Issuance of Operating License NPF-15, San Onofre Nuclear Generating Station, Unit 3, Docket No. 50-362, dated November 15, 1982.

Deviations to 10 CFR 50, Appendix R that have not been previously approved by the NRC.