ML13316A932
| ML13316A932 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/27/1986 |
| From: | Varga S Office of Nuclear Reactor Regulation |
| To: | Southern California Edison Co |
| Shared Package | |
| ML13316A931 | List: |
| References | |
| NUDOCS 8607090444 | |
| Download: ML13316A932 (7) | |
Text
[7590-01]
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
SOUTHERN CALIFORNIA EDISON COMPANY,
)
SAN DIEGO GAS & ELECTRIC COMPANY,
)
Docket No. 50-206 (San Onofre Nuclear Generating
)
Station, Unit No. 1)
)
EXEMPTION I.
The Southern California Edison Company (SCE) and San Diego Gas & Electric Company (SDG&E) (the licensees) are the holders of Provisional Operating License No. DPR-13, which authorizes operation'of the San Onofre Nuclear Generating Station, Unit No. 1, the facility. The license provides, among other things,
,that the facility is subject to all rules, regulations and Orders of the Nuclear Regulatory Commission (the Commission) now or hereafter in effect.
The facility is a pressurized water reactor located in San Diego County, California.
II.
On November 19, 1980, the Commission published a revised Section 10 CFR 50.48 and a new Appendix R to 10 CFR Part 50 regarding fire protection features of nuclear power plants (45 FR 76602). The revised Section 50.48 and Appendix R became effective on February 17, 1981.Section III of Appendix R contains fifteen subsections, lettered A through 0, each of which specifies requirements for a particular aspect of the fire protection 8607090444 860627 PDR ADOCK 05000206 F
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-2 features at a nuclear power plant. Subsections III.G.2 and III.G.3 dealing with maintaining one train of a redundant system free of fire damage and alternative or dedicated shutdown capability are the specific areas of the regulation where exemptions are requested by the licensees.
III.
By letter dated October 4, 1985, the licensees requested exemptions from Section III.G of Appendix R. Subsequently, on November 14 and 15, 1985, a meeting was held between the NRC and the licensees in Bethesda, Maryland, for the purpose of reviewing the Appendix R exemption requests. By letter dated December 10, 1985, the NRC requested additional information from SCE. In response to this request and to issues raised during the November meeting, the licensees submitted, by letters dated December 31, 1985, and April 23, 1986, exemption requests and responses to NRC questions. By letter dated May 12, 1986, the licensees submitted the "special circumstances" finding required by 10 CFR 50.12(a),
(see 50 FR 50764).
Finally, by letter dated May 30, 1986, a group of seven exemption requests were submitted to NRC which became necessary after a fire protection audit was conducted from May 19th through May 23rd 1986. Two of these were revisions of previously requested exemptions.
There are technical exemption requests for fifteen fire areas/zones which we have found acceptable. The details of our review are contained in the staff's related Safety Evaluation as published below. The fire area/zone numbering system used below corresponds to that used in the licensees' sub mittals and in our Safety Evaluation.
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-3 In regard to 10 CFR 50.12(a), the licensees stated in their letter of May 12, 1986:
"Also, implementing additional modifications to provide fire detection systems, fixed suppression systems and independence in these fire areas/zones would result in an unnecessary burden upon SCE for the following reasons:
- 1. The capital cost associated with engineering and installation of additional fire protection modifications.
- 2. The operational costs associated with the increased surveillance and maintenance on the additional fire protection equipment.
- 3. The additional engineering analysis and possible resulting modifications involved in the potential impact of spurious operation or rupture of fire suppression systems on safety related equipment and normal operations.
"Based upon the above discussion, SCE has determined that the costs associated with compliance in these fire area/zones are not commensurate with the resulting improvement in the ability to safely shutdown the plant after a fire and are in excess of those required to meet the underlying purpose of the rule. Therefore, the submitted requests for exemption meet the requirements of 10 CFR 50.12 paragraph (a)(2)(ii) in that special circumstances are present.
Further, it is concluded that the granting of these exemptions would not present an undue risk to the public health and safety, and are consistent with the common defense and security."
The staff concludes that "special circumstances" exist for the licensees' requested exemption in that application of the regulation in this particular circumstance is not necessary to achieve the underlying purposes of Appendix R to 10 CFR Part 50. See 10 CFR 50.12(a)(2)(ii).
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-4 The fifteen areas/zones and the sections of Appendix R for which exemptions are requested are:
Section III.G.3 Reactor Auxiliary Building, Lower Level [Fire Zone 1-AB-(-3)-2A]
Reactor Coolant Filter Enclosure [Fire Zone 1-AB-20-2N]
East Penetration Area [Fire Zone 1-YD-20-4A]
West Penetration Area [Fire Zone 1-YD-20-4B]
Yard Area [Fire Zone 1-YD-14-4D]
Circulating Water Pump Well [Fire Zoneil-YD-(-7)-4E]
Turbine Building, Ground Floor [Fire Zone 1-TB-8-9A]
Turbine Deck [Fire Zone 1-TB-35-9B]
Control Room Complex [Fire Area 1-PB-42-16]
Power Block Roof [Fire Area 1-PB-56-33]
Containment [Fire Area 1-CO-(-10)-1]
Section III.G.2.b Doghouse [Fire Zone 1-YD-20-4C]
Condensate Storage Tank Area [Fire Zone 1-YD-14-4F]
Main Transformer Area [Fire Zone 1-TB-20-9D]
Ramp Area [Fire Zone 1-TB-14-9E]
Exemption Requested Exemptions were requested for ten areas/zones from Section III.G.3 to the extent that it requires installation of fire detection and fixed fire suppres sion systems in the areas for which an alternative shutdown or dedicated shut down capability is provided.
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-5 Based on Section 2.0 of the Safety Evaluation published below, we conclude that the existing fire protection features in conjunction with the proposed modifications and the availability/independence of the dedicated or alternative shutdown capabilities for the above described fire areas/zones provide an ade quate level of protection equivalent to the technical requirements of Section III.G.3 of Appendix R. Therefore, the above ten exemptions are granted.
Exemption Requested In addition, there is a single technical exemption request for a fire area inside containment for Fire Area 1-CO-(-10)-1. This exemption was re quested from Section III.G.3 to the extent that it requires installation of full area fire detection and fixed fire suppression systems in the areas for
'which a dedicated shutdown capability is provided. An exemption was requested to the extent that the instruments providing indication at the dedicated shut down panel and the dedicated-shutdown pressurizer.heater cables at the pres surizer are not independent of the fire area under consideration.
Based on Section 3.0 of our Safety Evaluation, we conclude that the exist ing and committed fire protection features combined with the dedicated shutdown capability provide a level of protection equivalent to the technical requirements of Section III.G.3 of Appendix R. Therefore, the exemption is granted for Fire Area 1-CO-(-10)-1.
Exemption Requested Exemptions were requested for four areas/zones from Section III.G.2 to, the extent that it requires the separation of redundant safe shutdown components by a horizontal distance of more than 20 feet with no intervening combustibles, and automatic fire detection and fire suppression systems.
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-6 Based on Section 4.0 of our Safety Evaluation, we conclude that the existing fire protection features provide an adequate level of protection equivalent to the technical requirements of Section III.G.2 of Appendix R for these areas. Therefore, these exemptions are granted.
IV.
Accordingly, the Commission has determined pursuant to 10 CFR 50.12(a),
that (1) these exemptions as described in Section III are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and'security, and (2) special circumstances are present for these exemptions in that application of the regulation in these particular circumstances is not necessary to achieve the underlying purposes of Appendix R to 10 CFR Part 50. Therefore, the Commission hereby grants the exemption requests identified in Section III above.
Pursuant to 10 CFR 51.32, the Commission has determined that the issuance of this exemption will have no significant impact on the environment (51 FR 18521, May 20, 1986) and (51 FR 21429, June 12, 1986).
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-7 The licensees' requests dated October 4 and December 31, 1985, April 23, May 12 and May 30, 1986 and the staff's contractor's technical evaluation report dated April 23, 1986 are available for public inspection at the Com mission's Public Document Room, 1717 H Street, N.W., Washington, D.C. 20555, and at the Main Library, University of California at Irvine, Irvine, California 92713.
This Exemption is effective upon issuance.
FOR THE LE EGULATORY COMMISSION even ag,
c rector
- p.
-Division of PWR icen i -A Dated at Bethesda, Maryland this 27thday of Jun1986.