ML13330A207

Requests Extension to 811117 for Completion of Fire Protection Features Re Water Suppression Sys,Fire Barriers, Fire Dampers,Fire Barrier Penetrations & Water Damage Protection

ML13330A207
Person / Time
Site:	San Onofre
Issue date:	02/10/1981
From:	Baskin K Southern California Edison Co
To:	Crutchfield D Office of Nuclear Reactor Regulation
References
RTR-NUREG-0485, RTR-NUREG-485, TAC-48143 NUDOCS 8102120064
Download: ML13330A207 (4)

Text

Southern California Edison Company P. 0.

BOX 800 2244 WALNUTGROVEAVENUE ROSEMEAD. CALIFORNIA 91770 K. P. BASKIN TELEPHONE MANAGER OF NUCLEAR ENGINEERING, February 10, 1981 (213) 572-1401 SAFETY, AND LICENSING Director, Office of Nuclear Reactor Regulation Attention: D. M. Crutchfield, Chief Operating Reactors Branch No. 5 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C.

20555 Gentlemen:

Subject:

Docket No. 50-206 Fire Protection Program Review San Onofre Nuclear Generating Station Unit 1 The new Fire Protection regulations 10 CFR 50.48, which were published in the Federal Register on November 19, 1980, will become effective on February 17, 1981.

Regulation 10 CFR 50.48(d) requires completion of those Fire Protection features accepted by the NRC staff in Fire Protection Safety Evaluation Reports (SER for San Onofre Unit 1 dated July 19, 1979) by the date determined by paragraphs (d)(1) through (d)(4) of 10 CFR 50.48. Based on the date of issuance of the Fire Protection SER of July 19, 1979, the new regulations indicate that modifications not requiring station shutdown should have been installed by July 19, 1980 and those modifications requiring station shutdown should be installed during the current outage.

The modifications affected by 10 CFR 50.48(d) had previously been scheduled for completion (as indicated in the SER) in conjunction with any related station modifications resulting from the Systematic Evaluation Program (SEP).

Based on the present SEP schedule as indicated in NUREG-0485 dated December 1, 1980, a draft SER for the SEP will be issued on April 30, 1982.

Therefore, the Fire Protection modifications affected by 10 CFR 50.48(d) were deferred until at least after April 30, 1982 in the Fire Protection SER.

The new regulations of 10 CFR 50.48 in effect rescheduled modification requirements which were previously accepted for installation at least one year in the future and requires that they be installed 7 months in the past in relation to the effective date of the Regulations (February 17, 1981).

This, of course, is a schedule that cannot be met and would result in a violation of 10 CFR 50.48 once the new regulations became effective on February 17, 1981.

810 2.12 oc)(

D.

February 10, 1981 It is, therefore, respectfully requested that the completion date for the affected items, as identified in the enclosure to this letter, be extended as specified in 10 CFR 50.48(d).

The extension requests for each item of the enclosure is consistent with the required completion dates of paragraphs (c)(1) through (c)(4) of 10 CFR 50.48. Since these items do not require station shutdown, they are requested to be deferred to November 17, 1981 (9 months after the effective date of 10 CFR 50.48).

This extension request is justified since a large number of Fire Protection modifications have already been completed as indicated in the schedule included in Table 3.1 of the Fire Protection SER. In addition, measures have been taken to assure safe shutdown on an interim basis, by the installation of an additional source of offsite power, modifications to the station air system, provision for isolation capability of affected control systems and development of station procedures. These measures are discussed in the Fire Protection SER. The already installed Fire Protection modifications, in conjunction with the interim measures installed for safe shutdown, provide adequate assurance that the health and safety of the public will not be affected in the interim period until the modifications identified in the enclosure to this letter are completed.

In addition to the items described in the enclosure to this letter, three modifications to which Appendix R to 10 CFR 50 is not applicable and which have now been approved for implementation in accordance with the NRC letter dated February 4, 1981 (SER Supplement No. 1) will be completed by February 4, 1982 (1 year after approval) as required by 10 CFR 50.48(d)(2).

These three items include the modifications to the fire pumps to provide test features which meet the requirements of NFPA 20 (Item 3.1.2 of SER), the additional water feed and isolation valves for the north turbine building Fire Protection water systems header (Item 3.1.5d of SER), and the Halon system for the 480 volt switchgear room.

The modifications to which Appendix R to 10 CFR 50 is applicable include Fire Protection of safe shutdown capability, emergency lights, fire detection systems, and the reactor coolant pump lube oil collection system.

Our ability to meet these requirements by the schedules indicated in 10 CFR 50.48(c) is presently under review. If these requirements cannot be met, we will notify you as specified in 10 CFR 50.48.

As a result of discussion held with memebers of the NRC staff, it has been determined that this request for extension is a Class III fee type.

The basis for this determination is that this request involves a single safety issue and is deemed not to involve significant hazards consideration.

Accordingly, the fee of $4,000.00 corresponding to this determination is remitted herewith as required by 10 CFR 170.22 by Southern California Edison Company's Check No. T020630 dated February 11, 1981

D.

February 10, 1981 If you have any questions or desire additional justification for approval of this request, please contact me.

Sincerely, Enclosure

ENCLOSURE SER*

COMPLETION ITEM NO.

DESCRIPTION DATE 3.1.5 Water Suppression Systems The deluge system protecting the hydrogen seal oil unit 11/17/81 will be replaced with an automatic foam or water suppression system.

3.1.11 Fire Barriers Fire stops will be 'provided for cable trays at the 11/17/81 entrances to the pipe tunnel.

The roof and door of the oil storage shed in the east 11/17/81 feedpump area of the turbine building will be replaced to provide a 3-hour fire rating.

3.1.12 Fire Dampers Fire dampers will be provided in the ventilation 11/17/81 openings from the 480 volt switchgear room.

Fire dampers will be provided in the ventilation 11/17/81 penetrations to the battery rooms.

3.1.13 Fire Barrier Penetrations (3) Cable penetrations for the 480 volt switchgear 11/17/81 room.

(4) Cable penetrations from the dc switchgear room to 11/17/81 the administration and control building.

3.1.14 Water Damage Protection Water spray shields will be provided for electical 11/17/81 equipment in the 4160 and 480 volt switchgear rooms to prevent damage due to the use of hose streams to combat fires in cable trays above equipment.

SER -

Fire Protection Safety Evaluation Report date July 19, 1979.