ML13331A877
| ML13331A877 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/12/1986 |
| From: | Medford M Southern California Edison Co |
| To: | Lear G Office of Nuclear Reactor Regulation |
| References | |
| TAC-54880 NUDOCS 8605140101 | |
| Download: ML13331A877 (3) | |
Text
REGULATOR#INFORMATION DISTRIBUTION STEM (RIDS)
ACCESSION NBR:8605140101 DOC.DATE: 86/05/12 NOTARIZED: NO DOCKET #
FACIL:50-206 San Onofre Nuclear Station, Unit 1, Southern Californ 05000206 AUTH.NAME AUTHOR AFFILIATION MEDFORD,M.O.
Southern California Edison Co.
RECIP.NAME RECIPIENT AFFILIATION LEARG.E.
PWR Project Directorate 1
SUBJECT:
Requests exemption from new requirements of 10CFR50.12 re fire protection.Implementation of addl mods to provide fire detection & fixed suppression sys will result in expense w/o justifiable increase in safety.
DISTRIBUTION CODE: AO1D COPIES RECEIVED:LTR
_ ENCL &
SIZE: _
TITLE: OR Submittal: General Distribution NOTES:License Exp date in accordance with 10CFR2,2.109.
05000206 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PWR-A ADTS 1
PWR-A EB 1
PWR-A EICSB 2
PWR-A FOB 1
PWR-A PD1 PD 01 5
DUDLEY,R 1
PWR-A PSB 1
PWR-A RSB 1
INTERNAL: ADM/LFMB 1
ELD/HDS2 1
N
__DHT/TSCB 1
NRR/ORAS 1
04 1
RGN5 1
1 EXTERNAL: 24X 1
EG&G BRUSKE,S 1
1 LPDR 03 1
NRC PDR 02 1
1 NSIC 05 1
TOTAL NUMBER OF COPIES REGUIRED: LTTR 24 ENCL
£00
V*
Southern California Edison Company P. 0.
BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 M.O.MEDFORD TELEPHONE MANAGER. NUCLEAR LICENSING (818) 302.1749 May 12, 1986 Director, Office of Nuclear Reactor Regulation Attention: G. E. Lear, Director PWR Project Directorate No. 1 U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Gentlemen:
Subject:
Docket No. 50-206 Fire Protection Exemption Requests 10 CFR 50.12 Requirements San Onofre Nuclear Generating Station Unit 1
References:
- 1) Letter M. 0. Medford, SCE, to 3. A. Zwolinski, NRC, dated October 4, 1985
- 2) Letter M. 0. Medford, SCE, to G. E. Lear, NRC, dated December 31, 1985
- 3) Letter M. 0. Medford, SCE, to G. E. Lear, NRC, dated April 23, 1986 Reference 1 submitted requests for exemption from the requirements of 10 CFR 50 Appendix R III.G for San Onofre Unit 1. Reference 2 submitted an additional exemption request for containment fire area 1 and revision 1 of the yard fire zone 4D request. Reference 3 submitted revision 1 to the containment fire area request and revision 2 of the yard fire zone exemption request. Since the original exemption requests were submitted prior to the adoption of the new 10 CFR 50.12 requirements, the submitted requests did not specifically address these new requirements.
The purpose of this letter is to address the new requirements of 10 CFR 50.12, Specific Exemptions.
The technical bases provided in the fire area/zone exemption requests and III.G evaluations demonstrate that special circumstances are present such that application of the regulations in San Onofre Unit 1's particular circumstances is not necessary to achieve the underlying purpose of the requirements of 10 CFR 50 Appendix R III.G.3.
As stated in 10 CFR 50 Appendix R, the purpose of III.G.3 is to assure that alternative or dedicated shutdown capability and its associated circuits are independent of the fire area/zone under consideration so that these systems remain free of fire damage and are available to safely shutdown the plant. The III.G.3 requirements to provide fire detection and a fixed 8605140101 860512 04 PDR ADOCK 05000206 F
PDR I
AO0
Mr. G.
May 12, 1986 fire suppression system in the area/zone under consideration are intended to limit the extent of fire damage on the ability to safely shutdown the plant.
The submitted requests for exemption for fire area/zones 1, 2A, 4A, 4B, 4E, 9A, 9B, 16 and 33 seek relief from the III.G.3 requirements to provide fire detection and fixed suppression in the fire area/zones under consideration.
These requests for exemption provide the technical bases to demonstrate that the addition of fire detection and fixed suppression in the fire area/zones under consideration would not enhance, to a significant degree, the protection of safe shutdown functions due to the special circumstances of each individual fire area/zone. The request for exemption for fire area 1 from the requirement of 10 CFR 50 Appendix R III.G.3 that the dedicated instruments and equipment be independent of the fire area, provides the technical bases to justify that adequate separation and fire protection have been provided for the dedicated instruments and equipment which are located in this fire area.
Also, implementing additional modifications to provide fire detection systems, fixed suppression systems and independence in these fire area/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.
If you have any questions or require further comments, please contact me.
Very truly yours, cc:
F. R. Huey