ML13333B331

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Summary of 851114 Meeting W/Licensee to Discuss App R Compliance Review,Including Design of Dedicated Shutdown Sys,Review of Exemptions from NRC Requirements Submitted or Pending & Possible Deviations from NRC Guidance
ML13333B331
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 01/17/1986
From: Dudley R
Office of Nuclear Reactor Regulation
To:
Office of Nuclear Reactor Regulation
References
TAC-64883, NUDOCS 8601240159
Download: ML13333B331 (73)


Text

Docket No. 50-206 JAN 17 LICENSEE:

Southern California Edison Company FACILITY:

San Onofre Nuclear Generating Station, Unit 1 (SONGS-1)

SUBJECT:

SUMMARY

OF MEETING TO DISCUSS APPENDIX R (FIRE PROTECTION) AT SONGS-1 On November 14, 1985 the NRC staff met with licensee representatives to discuss the Appendix R compliance review for San Onofre, Unit 1. Discussions during the meeting centered around the area-by-area review for compliance with Section III.G of Appendix R, the design of the dedicated shutdown system (DSS), a review of exemptions from NRC requirements that have been submitted or are pending, and a discussion of possible deviations from NRC guidance.

The licensee committed to submit additional information to the NRC in response to specific questions regarding the DSS design and to clarify certain exemption requests.

A list of attendees is provided as Enclosure 1. Copies of handouts provided are included as Enclosure 2.

Richard Dudley, Project Manager Project Directorate #1 Division of PWR Licensing-A

Enclosures:

1. List of Attendees
2. Handouts cc w/enclosures:

See next page Office:

PD/PD#1: PWR-A Surname: Duey/tg G. Lear Date:

1/11/86 1/11/86 8601240159 860117 PDR ADOCK 05000206 PDR JAN 19 6 Mr. Kenneth P. Baskin San Onofre Nuclear Generating Station Southern California Edison Company Unit No. 1 cc Charles R. Kocher, Assistant Joseph 0. Ward, Chief General Counsel Radiological Health Branch James Beoletto, Esquire State Department of Health Southern California Edison Company Services Post Office Box 800 714 P Street, Office Bldg. 8 Rosemead, California 91770 Sacramento, California 95814 David R. Pigott Mr. Hans Kaspar, Executive Director Orrick, Herrington & Sutcliffe Marine Review Committee, Inc.

600 Montgomery Street 531 Encinitas Boulevard, Suite 105 San Francisco, California 94111 Encinitas, California 92024 Mr. Stephen B. Allman Mr. Kenneth P. Baskin, Vice President San Diego Gas & Electric Co~ppany Nuclear Engineering P. 0. Box 1831 Safety and Licensing Department San Diego, California 92112 Southern California Edison Company 2244 Walnut Grove Avenue Resident Inspector/San Onofre NPS P.O. Box 800 c/o U.S. NRC Rosemead, California 91770 P. 0. Box 4329 San Clemente, California 92672 Mayor City of San Clemente San Clemente, California 92672 Chairman Board of Supervisors County of San Diego San Diego, California 92101 Director Energy Facilities Siting Division Energy Resources Conservation &

Development Commission 1516 -

9th Street Sacramento, California 95814 Regional Administrator, Region V U.S. Nucle-Reg' tory Co7mssicn 1450 Maria Lane Walnut Creek, California 94596

ENCLOSURE 1 SAN ONOFRE FIRE PROTECTION MEETING NOVEMBER 14, 1985 NAME AFFILIATION Richard Dudley PAD#1 R. Ornelas SCE, Licensing T. L. Roell FLVOR Jack Rainsberry SCE, Licensing David Barreres SCE, Station Peter Hypnar Impell James Conway Impell Richard Cupp Impell Jeff Yann SCE, PE N. Ahmed FRC Greg Harrison, P.E.

Self John Stang ORB#5

AGENDA NCLOSURE 2 APPENDIX R CCEPLIANCE SAN ONOFRE UNIT 1 NOVEBER 14, 1985 A.

INTRODUCTION (SCE)

B.

SHUTDO METHODS USED (IMPELL)

C.

SECTION III.G COMPLIANCE REVIEW (IMPELL)

D.

DSS DESIGN (FLUOR)

E.

SPMARY REVIEW OF SUHITTED DEEPTIONS (IMPELL)

F.

PENDING EXEM1PTIONS (IMPELL)

G.

DEVIATIONS FRE NRC GUIDANCE (IUPELL)

APPENDIX R CCEPLIANCE SCE SUBMITTALS TO NRC SA ON0FRE UNIT 1 0

APRIL-24, 1984 - DEDICATED SHUTDOWN APPROACH CONCEPTUAL DESIGN DESIGN CALCULATIONS 0

MAY 21, 1985 - RESPONSE TO NRC QUESTIONS AND NEW DESIGN INFO ADD CHARGING MINIFLOW USE PRESSURI2ER HEATERS AFWS FLOW - 375 GPM 0

OCTOBER 4, 1985 - GL81-12 INFO14ATION AND DEEPTIONS 0

JANUARY 15, 1986 - EXPECTED DATE OF FINAL SLBITTAL

DSS PRESENTATION T. L. ROELL NOVEMBER 14, 1985 o

OBJECTIVE OF DSS (DSD) o DESIGN CRITERIA o

CHANGES SUBSEQUENT TO 4/84 SUBMITTAL o

SYSTEM FUNCTIONAL DESIGN o

BLOCK DIAGRAM o

SYSTEM GENERAL ARRANGEMENTS o

SUMMARY

11/11/85 015/923003/054

DSD KEY DESIGN FEATURES o

CHARGING PUMP o

AUXILIARY FEEDWATER PUMP o

PRESSURIZER HEATERS o

STEAM 'DUMP o

SINGLE PHASE SECONDARY LETDOWN o

DIESEL GENERATOR 0

CONTROL PANEL 11/11/85 015/923003/054

I I

Doe REACTIVITY CONTROL L- -1 SCHEMATIC DIAGRAM sou Axnto

-IT CRM27 f

__i1 1* REOWIRES BACK-UP N2 r~~~~2 nu-40NjI

- D8S BOUNDARY rMOV-868 In

CROC1 Do m0*

0.---

DSS PLOW PATH caeAMse Pou, usc LeW

4. MANUAL VALVE$ USED FO FYOLATING DO$ BOUNDAR o wI cNOT SOWNc v a
  • .v P

vIsPINoG-*

-s e

'.s 10- 0y S. VALVE POSITION SOWN Ic M

pm R DOS MODE L, MOV -sa Mx cV 415 0-OPEN TO 11A0ea-LOOPE v v csov I l&C 11168 III&A IG, cootaper

(

PUMP 316-

"aa OF (ALTEFACIL

  • NOTE*P

-EALS (8)8 CCW

.A DX FCLER PA 4.ERMAL MALR VV EMERGENC CLOSED noen

DSD DESIGN EVOLUTION FROM APRIL 1984 REACTIVITY CONTROL SUBMITTAL DATE 0

ADD CHARGING PUMP RECIRCULATION LINE FOR 5/85 LOW FLOW INJECTION CONTROL DELETE CHARGING PUMP ROOM THERMAL BARRIER 10/85 AND HEAT SHIELD 11/11/85 015/923003/054

PRIMARY COOLANT INVENTORY CONTROL SCHEMATIC DIAGRAM MAY REOMANAR CRS*C27 I R1.*REOUIRES SACK-UP N2 M 0*- 1Sa L *-DS8 BOUNDARY M MOV-8888 Lm d

CR 1
  • S. ---- DS FLOW PATH L

LCH !N4 P.c.

c..

J M

4. MANUAL VALVES USED FOI ISOLATING D88 BOUNDARY Sof I NOT SHOWN.

- Y VALVE POSITION SHOWN IK I.

In L

FOR DS MODE Le.,

PUov 0up MI ace p

ac M*

OPEN I

o

      • A aserV WWIN 0v

- -0o10 CLOSED

.my my m

Ilse0 11"6 lit"S 988MA titC 98 ttS on up MOV-Stooc T To C"m Loo to namse oouf PUMP SEAL8(3)

TO MRAL 11MTWR

.t

-V S16C NUTl" wem~u a PCI cy ov IC CCW MSAT ExcAM Ccw PUMP m RME"eNCY COOLase I

DSD DESIGN EVOLUTION FROM APRIL 1984 INVENTORY CONTROL SUBMITTAL DATE 0

THERMAL BARRIER COOLING PUMP NOT REQUIRED 10/85 PROVIDE REMOTE CONTROL OF FCV-1112 FROM 10/85 C-38 e

PROVIDE N2 BACKUP FOR FCV-1112 FROM C-38 10/85 2 003/054

PRIMARY COOLANT PRESSURE CONTROL SCHEMATIC DIAGRAM sV 8403 PCV 430H RCS FLASHIPOT

6.

LOOP A l=

COLD LEG s V 24O PCV 490C lopCOL LEG CV-53 cv am PRESSURIZER CHARIN 40VAPOR RC PUMP SAMPLE 0e PMP 29 TI

  • o.

412B STEAM n iOy RcC-1 c LD in GENERATOR 412A22 Des.E-18 o

4 CV-648 h17 LOPBHToE V64 ECO LI CIAI 2

Rem FoPRESSURIZERDAdHAERNOE IL1.F TREQUIRE BACK-UP N2 L If-088 BOUNDARY

& - -- DB8 FLOW PATH CV-88o

4. MANUAL VALVES USED FOR CV-840 NEISOLATING 088 BOUNDARY, INTERMITTENT USE ONLY PRESS NOT sHowN.

HEATER L. VALVE POSmTON 8NOWN I8 gas ORO UP D FOR DSS MODE L*,M-OPEN PRIMARY

)(-OCLO PLANT

MAKE-UP CV "a LOOP 8 HOT LEG CV "S WAEACTOR WATER
COOLANT PC DcR AIN TANK

/

CV 642 DRI HEDRS YSTEM PRE88URIZR*Am RELIEF TANK FC

DSD DESIGN EVOLUTION FROM APRIL 1984 PRESSURE CONTROL SUBMITTAL DATE 0

DELETED N2 HARD BUBBLE IN THE PRESSURIZER 5/85 AND VALVE CV-953.

0 POWER HEATER BANK D FROM DSD 5/85 11/11/85 015/923003/054

DECAY HEAT REMOVAL -

STEAMiNG MODE unsu%

MoM SCHEMATIC DIAGRAM

-m" a

olr TO ATMOAMA

-- A-II TEAM GENERATOR I

E-10 c

TuRsms MAm ATOP VALVB

-im u

s-m e

r4 TYP ROUTE FOR SC-lSO 6-STEAM ENERATORS E-18 1aseco 10 m

ame PCV IA* SATO

1. 0 REQUMRES BACK-4

-N2 L M-D88 BOUNDARY D68 FLOW PATH U

4. MANUAL VALVE8 USED FOR.

E -1 A jt9-1 WOLATIN D68 BOUNDARY.

.g~g NOT &HQWN

.y-6 6; VALVE POSITION SHOWN 0 FOR D88 L0.. IM* OPEN STEAM DUMP TO ATMOSPHEE 04-CLOSED M O D E v T r v T e lAI STEAM TO TINW E 188U<@i 1

DSD DESIGN EVOLUTION FROM APRIL 1984 STEAMING MODE SUBMITTAL DATE ADD THIRD AUXILIARY FEEDWATER PUMP (G-10w),

10/85 PIPING, AND CONTROLS 4N PLACE OF AUXILIARY FEEDWATER PUMP G-10S NOT USED USE AUXILIARY FEEDWATER FLOW RATE OF 5/85 375 GPM INSTEAD OF 400 GPM.

0 DELETE STEAM HEADER PRESSURE TRANSMITTER FROM C-38 PANEL.

PRESSURE GAGE IN SECONDARY LETDOWN LINE TO BE USED 1 1/11/85 015/923003/054

DECAY HEAT REMOVAL dSINGLE PHASE COOLING MODE SCHEMATIC DIAGRAM STEAM p F GENERATOR u

TAWK c

L I

.Oro VI m

=

l mew rev I

I owy f#Y noura Fom b-Srau asuanATORs DISCHARGE TO CIC. WATER am1L OL NOTES UNDER DECAY HEAT REMOVAL-STEAMINC a u "a

"MODE APPLY.

MEW PWS SEAM SUPPLY

-1 /D8 AFWP TURBIE r-Tr SQTANMN~

I ro was rusa

DSD DESIGN EVOLUTION FROM APRIL 1984 SINGLE PHASE MODE SUBMITTAL DATE

--DELETE RADIATION MONITOR AT LETDOWN LINE 10/85 11/11/85 015/923003/054

j 2

j I

s I

6 9 '10 II 12


-~"

e---o e

Fr-*

ot o

1--

0-OSRAMVCIasM Smi4

  • r sys7 ta eg aperat dea1050.- -

-m

DSD DESIGN EVOLUTION FROM APRIL 1984 ELECTRICAL AND MISCELLANEOUS SUBMITTAL DATE O

RELOCATE SWITCHGEAR, CONTROL PANEL C-38, AND 10/85 DIESEL GENERATOR TO NEW STRUCTURES WEST OF THE REACTOR AUXILIARY BUILDING 0

USE INDOOR SWITCHGEAR TYPE 10/85 0

INSTALL NEW DIESEL FUEL TANK. ABANDONED TANK 10/85 WILL NOT BE USED 0

USE A 2000 KW DIESEL IN PLACE OF A 1000 KW UNIT 10/85 EXISTING DIESEL DRIVEN AIR COMPRESSORS NOT 10/85 REQUIRED 0

ADD THREE HOT LEG TEMPERATURE TRANSMITTERS 10/85 0

USE NEW DEDICATED CONTAINMENT PENETRATIONS FOR 10/85 DSD CIRCUITS 0

REWIRE ALL DSD CIRCUITS INSIDE CONTAINMENT WITH 10/85 SEPARATE CONDUIT AND ONE HOUR FIRE RATED CABLE 11/11/85 015/923003/054

DEDICATED SHUTDOWN SYSTEM INSTRUMENTATION AT C-38 PANEL O

PRESSURIZER PRESSURE INDICATOR o

PRESSURIZER LEVEL INDICATOR 0

"A" STEAM GENERATOR LEVEL INDICATOR 0

"B" STEAM GENERATOR LEVEL INDICATOR 0

"C" STEAM GENERATOR LEVEL INDICATOR 0

LooP "A" REACTOR COOLANT TEMPERATURE INDICATOR (COLD LEG) o LooP "B" REACTOR COOLANT TEMPERATURE INDICATOR (COLD LEG) 0 LOOP "C" REACTOR COOLANT TEMPERATURE INDICATOR (COLD LEG) o STEAM DUMP CONTROLLER (CV-76 THROUGH CV-79) 0 SWITCH:

STEAM DUMP CONTROL TRANSFER 0

LooP "A" REACTOR COOLANT TEMPERATURE INDICATOR (HOT LEG) 0 LooP "B" REACTOR COOLANT TEMPERATURE INDICATOR (HOT LEG) 0 LOOP "C" REACTOR COOLANT TEMPERATURE INDICATOR (HOT LEG) o CHARGING FLOW CONTROLLER (FCV-1112) 0 SWITCH: PRESSURIZER PORV CONTROL (CV-530 AND CV-546) o SWITCH: FCV-1112 CONTROL CAPTURE o

SWITCH: SV-176 CONTROL SEPARATION 11/11/85 015/923003/054

r

.,),

DO//

A--A---A-AT--.

2 I-pLu -

s~o Mae" I~

~ftoAK

-V ru,

-pie to.A PLAN T

L.3

-6 1e4ZC~.

wc viwai NA 1440GUR-1S0!

.,T.~LA AT 0 cL 1-0-o OR MATCHUIGUN S-II

MACPILIN! SEE FIGUREs -1

=

=

T9 S

~W~ &'esj PLAN AT CL. 20*-o

~

IL IL

-r__

  • ll 7-we-l W 4 APL&CONt2 MMAC A"AWA/

FIGURE 3-3

SONGS -1 SOUTHERN CALIFORNIA EDISON CO.

SHUTDOWN METHODS USED o SAFE SHUTDOWN SCENARIOS NORMAL ALTERNATE (ASO) bTHER PLANT EQUIPMENT IN LIEU OF NORMAL SSD MANUAL ACTUATION OF NORMAL SSD EQUIPMENT CONSISTENT WITH NRC GUIDANCE DEDICATED (DSS)

SONGS -1 SOUTHERN CALIFORNIA EDISON CO.

PLANT PHYSICAL CONFIGURATION o FIRE AREAS oFIRE ZONES PREVIOUSLY DISCUSSED WITH NRC EXTERIOR YARDS SPATIAL SEPARATION OF SSD EQUIPMENT LOCALIZED COMBUSTIBLES LOCALIZED FIRE PROTECTION

SONGS -1 SOUTHERN CALIFORNIA EDISON CO.

FIRE AREA NUMBERING EXPLANATION UNIT FIRE ZONE (Alphe Cheracter)

BUILDING ID FIRE AREA ID (Up to 3 digits)

ELEVATION (Lowest floor)

SONGS-1 Southern California Edison Co.

1g*--ic Cs JO-Dim 1-PB-56-33 (POWER BLOCK ROOF) pu- 0

-s1-PB-20-11A 1-PB-20-11A -- --

___.ur PARTIAL PLAN a 1:

1-TL3-as 9B AT 321-0"1 I-Ir rr A.

liiiso LEGEND:

Fire areah/zohes where dedicated

..shutdown may be required.

IFire areas/zones where alternate PLAN AT EL. 35'-6'1 Lshutdown may be required.

O Fire areas/zones where normal shutdown may be required.

ag Fire areas/zones where manual H actuation may be required

SONGS-1 Southern California Edison Co.

I-PS20-1 2 1-P-29-13C 1P-2 (ATTIC ABOVE 13B)

-I -PB-20-13B 20v J-PB-20-13A

> L

'Aq k

W Ir e aa1-e WWI*****0 WIM 1-YD-14C 0

1 D

m:::r 1**F 4-I*-**1 L41 I.I.

a announsensesoas-

--Fire areashZones where dedicated PLAN T EL 4L..QSIshutdown may be required.

PLAN AT.r reashones where alternate may be required.

Fireareashones where normal OI shutdown may be required.

Fire areas/zones where manual 0 actuatioan may be required.

SONGS-1 YD-20-4C Southern California Edison Co.

MATCHLINE SEE FIGURE 3 I 1 'kL W_ go

,-A 4.

-m

  • W~ll IMEOl

_;1 Von-O-Ill ErE 1-AB-202

.8

[-s...m a.1-YD-(-7)-4 I-AB-j3)-2A 1-YD-4-4 C

0 1-YD-20-4G PLAN AT EL. 20'-O" PACHLINE SEE-FIGURE-3-1 LL s G-AU-3D*2 r-

-AB-(-3)-24___

Wil"(

TAL "A

LEGEND:

Z Fire areas/zones where dedicated W r_

shutdown may be required.

PLAN BELOW EL. 20-0"1 O

rs areas/zones where alternate shutdown may be required.

Ol Fire areas/zones where normal shutdown may be required.

Fire areas/zones where manual actuation may be required

SONGS-i1 Southern Calilfornia Edison Co.

A 11 LEGEND:

-Fire areas/zones where dedicated shutdown may be required.

PLAN AT EL. 20'-61*

Fire areas/aones where alternate shutdown may be required.

oFire areas/zones where nermal shutdown may be required.

Fire areas/zones where manual actuation may be required

SONGS -1 SOUTHERN CALIFORNIA EDISON CO.

APPENDIX R, SECTION III.G COMPLIANCE REVIEW o GENERIC LETTER 81-12 o ENCLOSURE 1 ORGANIZATION INTRODUCTION METHODOLOGY AND SSD EQUIPMENT LIST FIRE AREA/ZONE DRAWINGSj APPENDIX R, SECTION III.G EVALUATION REFERENCES

~!

Zr.~

5 b..I jrrl ISE?_

00 SONGS -1 SOUTHERN CALIFORNIA EDISON CO.

APPENDIX Rr SECTION III.G EVALUATION FORMAT o ORGANIZED BY BUILDING ID THEN FIRE AREA/ZONE o EACH FIRE AREA/ZONE LISTS SSD COMPONENTS AND CIRCUITS LOCATED THEREIN.

o

SUMMARY

OF CONSEQUENCES TO SSD SYSTEMS PROVIDED o CIRCUIT EVALUATION ORGANIZED BY CATEGORIES HSB -

HOT STANDBY CSD -

COLD SHUTDOWN HLP -

HI/LO PRESSURE INTERFACE SOE -

SPURIOUS OPERATING EQUIPMENT ASD -

ALTERNATIVE SHUTDOWN DSS -

DEDICATED SHUTDOWN EACH CATEGORY ORGANIZED BY SSD SYSTEM ID CIRCUIT AND ITS FUNCTION CONSEQUENCES OF FIRE ON CIRCUIT OPERATION MITIGATION

(1CFR50 APPENDIX R,. SECtION III.G COMPLIANCE EtMLUATION FIRE AREA/ZONE 1-TD*20.48 West Penetration Area Effects of Fire on Safe Shutdown Capability A fire In this fire arealtone could result in the loss of the following portions of systems used to achieve hot standby and cold shutdown:

Reactor Coolant System (RCS)

Cables for the following components PURVs Block valves Pressurizer neaters

  • Source range monitors Pressurizer level transmitters Primary system temperature transmitters Chemical and Volume Control (CYCS)

Cables for the following components:

Charging pumps and associated support equipment Charginq loop A control valves Charging loop A flow transmitter Reactor coolant pump seal flow pressure transmitters Charginq RWST isolation valves Seal injection flow control valves Main Steam System (MSS)

Atmospheric steam dump valves Cables for the following components:

Atmospheric steam dump valves Steam generator level transmitters Auxiliary Feedwater System (AFU)

Cables for the following components:

Motor driven auxiliary feedwater pump Steam driven auxiliary feedwater pump Flow control valves lYl rri1 Revision 0

10CFR50 APPENDIX N, SECTION 111.6 COMuLIANCE EVALUATION FIRE AREA/1ONE 1-YO-20-40 West Penetration Area Component Cooling ater (CCW)

Cables for the following components:

Component cooling water pump CCU heat exchange isolation valve Thermal barrier outlet valves CCW RHR heat exhanger flow control valves Containment Ventilation System (CTS)

Cables for the following components:

Reactor cavityfcooling fan and associated damper Gaseous Nitrogen System (GN!)

Cables for the following components:

PORY nitrogen control valve Residual leat Removal (RHR)

Cables for the following components Residual heat removal pump Residual heat remuval inlet isolation valve Residual heat removal oischarge isolation valve RHR heat exchanger isolation valve NHR inlet and discharge temperature transmitters RHR flow control valve Essential Electrical Systems Station service transformer 3 Cables for the following components:

480? switchgear 120V vital buses Impll Corporation

10CFR50 APPENDIX A. SECTION III.6 COMPLIANCE tWALUATION FIRE AREA/ZONE 1-40-20-48 west Penetration Area The following portions of the dedicated shutdown system are located within the west penetration area:

Reactor Coolant System Cables for the following components:

primary system temperature transmitters pressurizer pressure transmitter pressurizer level transmitter Main Steem System (MS$)

Cables for tne follaping components*

steam generator level transmitters Cables for the dedicated snutdown system operation of pressurizer heater group 0, and the PURVs and their associated block valves will also be routed tnrough this tire area/zone.

The fire protection features provided for the protection and separation of safe shutdown systems within the fire area/zone do not meet the separation requirements of 10CFR5O Appendix R, Section 11I.6.2.

The dedicated shutdown system will be used to achieve and maintain cold shutdown in the event of a fire in the fire area/zone.

Operator action will be taken to locally control certain valves required for hot standby.

Operator action will also be taken to deenergize offsite and normal onsite power sources to prevent and mitigate spurious equipment operation.

An exemption request for the lack of area-wide suppression/detection per the requirements of Sections Il.G.3 will be provided.

Cables and equipment for the dedicated shutdown system which are routed through this fire area/zone will be protected by a 3-hour rated fire barrier.

The interruption of seat injection and seal cooling to the reactor coolant pumps, for the period required to initiate seal injection from the dedicated shutdown system, nas been evaluated and determined to be acceptaole (26).

The loss of auxiliary feedwater flow, for the period required to initiate auxiliary feedWdter flow from the dedicated shutoown system, has been evaluated and determined to be acceptable (24,25).

Impll Corpnration Revision 0

IOCFR5O APPENDIX

, SECtION II.s COMLIANCE EVALUATION FIRE AREA/ZONE 1-4D-20-46 West Penetration Area Uamage to cables for.PURY and its associated block valve could cause the spurious actuation of the PURV when the block valve is not availaole to isolate the line. bpurious actuation of the PURV, until operation action Is tacen to deenergite and close the valve, has been analyzed, and will not result in unacceptable consequences (24,25).

Damage to the cables for atmospheric steam dump valves CV-?

and CV-79 could cause the valves to spuriously open.

Spurious actuation of the valves, until operator action is taken to deenergize and close the valves, has been analyzed, and will not result in unacceptable consequences (24.25). The redundant steam dump valves CV-76 and CV-78 will remain available for dedicated shutdown system operation.

Damage to cables for the reactor vessel head vent valves and pressurizer hiqh point vent valves could cause the spurious actuation of the two redundant high/low pressure interface valves in each line.

Spurious actuation of these valves, until operator action is taken to deenergize and close the valves, has been analyzed, and will not result in an unacceptable consequences (24,25).

Damage to cable for primary plant makeup water control valve FCv-1102A could cause the valve to spuriously actuate, allowing primary plant water to be supplied directly to the charging pump suction.

Spurious actuation of this valve, until operator action is temen to deenergize and close the valve, has been analyzed and determined to be acceptable (27).

Uamage to cables for boric acid supply valves FCV-ilU28 and CV-334 could cause these valves to spuriously open, allowing concentrated boric acid to be supplied to the charging pump suction. Operator action will be required to close manual valves to isolate these lines.

Damage to cables for the containment spray control valve CV-I14 could cause this valve to spuriously open. Containment spray will not be inadvertently initiated, as the refueling water pumps will not be spuriously actuated by a fire in this fire area/zone.

Impell Corporation, U,.~.-.*

ag.,

ini~-l~~

YI-24Revision 0

IOCFR5O APPENDIX R, SECTION 111.6 CUMPLIANCE EVALUATION FIRE AREA/ZONE 1-YD-20-48 west Penetration Area Categry System Component Circuit-Schedule Function Consequence of Fire itigation Not 0!60V Bus IC, IAICiPi-KB Power to station service Loss of power to 480V switchgear 3 None.

Dedicated shutdown system will Standb Brkr 11 transformer 3 from station service transformer 3 remain available. Request exemption for lack of area-wide suppression/detection per Ill.G.3.

120Y 1-29 1GYV29P2-KC Power Loss of power to vital bus 5 Operator action to manually position could cause the loss of power FCV-3300 and FCV-3301 will be required.

to the following components Dedicated shutdown system will remain required for normal/alternate available.

shutdown:

LT-3400A TE-3402A FCV-3300 LJ-34006 TE-3411A FCV-3301 LT-3400C TE-3421A CV-3201 SV-32U0 SV-3204 SV-J214 SV-32U2 SV-3205 CV-3213 5V-3203 5-3211 TV-29/

160I2170-KC Power Loss of 1251 DC power to Uperater action to manually position Inverter 5 Inverter 5.

FCV-30 and FCV-3301 will be required.

Dedicated shutdown system will remain available.

RCS CV-531 IGY121SC1-KC Remote valve control Damae to this circuit could Operator action to deenergize 12OVAC/480VAC result In the loss of remote power to preventjmitigate spurious valve control, and/or cause the operation. CV-531 will fail open on loss of valve to spuriously close, or power.

open.

CV-545 IGY1215C0-KC Remote valve control Damage to this circuit could Operator action to deenergize 120YAC/480VAC prevent remote operation and/or power to prevent/mitigate spurious cause the valve to spuriously operation. CV-545 will fail closed on loss open or close.

of power.

Spurious operation of the PORV, until operator action is taken to deenergize and close the valve, has been analyzed, and will ndt result in an unacceptable condition (24.25).

161215C2-KC Remote valve control/

Damage to this circuit could position indication result in tne loss of remote valve control, and/or cause the valve to spuriously open, or close.

Impell Corporation 1-tryfl-?s Revision 0

SONGS -1 SOUTHERN CALIFORNIA EDISON CO.

SUMMARY

REVIEW OF SUBMITTED EXEMPTIONS PENDING EXEMPTIONS DEVIATIONS FROM NRC GUIDANCE

SONGS-I SOUTHERN CALIFORNIA EDISON CO.

EXEMPTIONS SUBMITTED EXEMPTION REQUESTED FROM IOCFR5O APPENDIX R SECTION SAFE SHUTDOWN RE AREA DESCRIPTION III.G.2b III.G.3.e SCENARIO TO BE USED I 'B-42-16 CONTROL ROOM S

ass 1 --PB-56-33 CONTROL BLOCK ROOF S

ASD 1-YO-0-4A EAST PENETRATIONSDS I-YD-2O-0A ES AREA S

ass 1-YO-20-48 WEST PENETRATION S

ass AREA 1-YO-14-40 YARD AREA S

S ASO 1-(D-(-7)-4E CIRC WATER S

ASO

!-TB-8-SA TURBINE BLOG*

S ass 1-TB8-9AGROUND FLOOR I-TB-35-98 TURBINE DECK S

ASO REACTOR AUXILIARY S

ASO 1-AB-(-3)-2A BLDG. LOWER LEVEL S = EXEMPTION SUBMITTED r r,- a ri /

i r-e~r

SONGS 1 SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION SUMPARY FOR FIRE AREA 1-PB-42-16 CONTROL ROOM EXEMPTION REQUESTED: 10CFR50 APPENDIX R, SECTION III.G.3A PROBLEM:

THE SEPARATION OF REDUNDANT TRAINS OF SAFE SHUTDOWN EQUIPMENT WITHIN THE FIRE AREA DOES NOT MEET THE REQUIREMENTS OF 10CFR50 APPENDIX R, SECTION III.G.2, DEDICATED SHUTDOWN CAPABILITY HAS BEEN PROVIDED FOR USE IN THE EVENT OF A FIRE IN THIS FIRE AREA. THE FIRE AREA DOES NOT MEET THE REQUIREMENTS OF SECTION III.G.3 OF APPENDIX R IN THAT PARTIAL AREA FIRE DETECTION IS PROVIDED IN THE FIRE AREA, AND A FIXED SUPPRESSION SYSTEM IS NOT PROVIDED IN THE FIRE AREA.

SONGS 1 SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION

SUMMARY

FOR FIRE AREA 1-PB-56-33 CONTROL BLOCK ROOF EXEMPTION REQUESTED: 10CFR50 APPENDIX R, SECTION III.G.3A PROBLEM: THE SEPARATION OF THE REDUNDANT TRAINS OF THE PRIMARY SYSTEM HOT LEG TEMPERATURE TRANSMITTERS WITHIN THE FIRE AREA DOES NOT MEET THE REQUIREMENTS OF 10CFR50'APPENDIX R, SECTION Ill.G.2.

ALTERNATIVE HOT LEG TEMPERATURE INDICATION IS AVAILABLE THROUGH THE USE OF THE PRIMARY SYSTEM DELTA T INSTRUMENTS IN THE CONTROL ROOM, OR THE USE OF THE HOT LEG TEMPERATURE INDICATORS AT THE DEDICATED SHUTDOWN PANEL. THE FIRE AREA DOES NOT MEET THE REQUIREMENTS OF SECTION Ill.G.3 OF APPENDIX R, IN THAT FULL AREA FIRE DETECTION AND FIXED FIRE SUPPRESSION SYSTEMS ARE NOT PROVIDED IN THE FIRE AREA.

SONGS 1 SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION

SUMMARY

FOR FIRE ZONE 1-YD-20-4A EAST PENETRATION AREA EXEMPTION REQUESTED: 10CFR50 APPENDIX R, SECTION III.G.3.A PROBLEM: THE SEPARATION OF REDUNDANT TRAINS OF SAFE SHUTDOWN EQUIPMENT WITHIN THE FIRE ZONE DOES NOT MEET THE REQUIREMENTS OF 10CFR50 APPENDIX R, SECTION III.G.2.

DEDICATED.SHUTDOWN CAPABILITY HAS BEEN PROVIDED FOR USE IN THE EVENT OF A FIRE IN THIS ZONE. THE FIRE ZONE DOES NOT MEET THE REQUIREMENTS OF SECTION III.G.3 OF APPENDIX R, IN THAT PARTIAL AREA FIRE DETECTION IS PROVIDED IN THE FIRE ZONE, AND A FIXED FIRE SUPPRESSION SYSTEM IS NOT PROVIDED WITHIN THE FIRE ZONE.

SONGS 1 SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION

SUMMARY

FOR FIRE ZONE 1-YD-20-4B WEST PENETRATION AREA EXEMPTION REQUESTED: 10CFR50 APPENDIX R, SECTION III.G.3A PROBLEM: THE SEPARATION OF REDUNDANT TRAINS OF SAFE SHUTDOWN EQUIPMENT WITHIN THE FIRE ZONE DOES NOT MEET THE REQUIREMENTS OF 10CFR50 APPENDIX R, SECTION III.G.2. DEDICATED SHUTDOWN CAPABILITY HAS BEEN PROVIDED FOR USE IN THE EVENT OF A FIRE IN THIS ZONE.

THE FIRE ZONE DOES NOT MEET THE REQUIREMENTS OF SECTION III.G.3 OF APPENDIX R, IN THAT PARTIAL AREA FIRE DETECTION IS PROVIDED IN THE FIRE ZONE AND A FIXED FIRE SUPPRESSION SYSTEM IS NOT PROVIDED IN THE FIRE

-UNL

SONGS I SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION

SUMMARY

FOR FIRE ZONE 1-YD-14-4D EXEMPTION REQUESTED:

IOCFR50 APPENDIX R, SECTION III.G.2.A AND III.G.2.B PROBLEM:

THE SEPARATION OF THE REDUNDANT STATION SERVICE TRANSFORMERS WITHIN THE FIRE ZONE DOES NOT MEET THE REQUIREMENTS OF 10CFR5O APPENDIX R. SECTION III.G.2.B THE STATION SERVICE TRANSFORMERS ARE SEPARATED BY APPROXIMATELY 150 FEET, INCLUDING APPROXIMATELY 40 FEET WITHOUT INTERVENING COMBUSTIBLES, HOWEVER FIRE DETECTION AND FIXED SUPPRESSION SYSTEMS ARE NOT PROVIDED THOUGHOUT THE FIRE ZONE.

THE SEPARATION OF CABLES FOR THE CHARGING PUMPS WITHIN THE FIRE ZONE DOES NOT MEET THE REQUIREMENTS OF 10CFR50 APPENDIX R. SECTION III.G.2. CABLES FOR ONE OF TRE CHARGING PUMPS WILL BE REROUTED OUTSIDE 'THE FIRE ZONE. AND THE INTERVENING CABLE TRAYS PROVIDED WITH FIRE STOPS. THE FIRE ZONE DOES NOT MEET THE REQUIREMENTS OF SECTION III.G.2.8 OF APPENDIX R. IN THAT FIRE DETECTION AND FIXED SUPPRESSION IS NOT PROVIDED THROUGHOUT THE FIRE ZONE.

THE SEPARATION OF THE COMPONENT COOLING WATER PUMPS.

AND CABLES FOR THE SALTWATER COOLING PUMPS DOES NOT MEET THE REQUIREMENTS OF 10CFR50 APPENDIX R. SECTION III.G.2. ALTERNATIVE SHUTDOWN CAPABILITY HAS BEEN PROVIDED. THE FIRE ZONE DOES NOT MEET THE REQUIREMENTS OF SECTION III.G.3 OF APPENDIX R IN THAT FIRE DETECTION AND FIXED SUPPRESSION IS NOT PROVIDED THROUGHOUT THE FIRE ZONE.

SONGS 1 SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION SUMM.ARY FOR FIRE ZONE 1-YD-(-7)-4E CIRC WATER PUM1P WELL EXEMPTION REQUESTED: 10CFR50 APPENDIX R, SECTION III.G.3.A PROBLEM: THE SEPARATION OF THE REDUNDANT SALTWATER COOLING PUMPS WITHIN THE FIRE ZONE DOES NOT MEET THE REQUIREMENTS'OF 10CFR50 APPENDIX R, SECTION III.G.2.

ALTERNATIVE SHUTDOWN CAPABILITY IS AVAILABLE THROUGH THE USE OF THE AUXILIARY SALTWATER COOLING PUMP (G-13C).

THE FIRE ZONE DOES NOT MEET THE REQUIREMENTS OF SECTION III.G.3 OF APPENDIX R, IN THAT FIRE DETECTION AND FIXED FIRE SUPPRESSION SYSTEMS ARE NOT PROVIDED THROUGHOUT THE FIRE ZONE.

SONGS 1 SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION

SUMMARY

FOR FIRE ZONE 1-TB-8-9A TURBINE BUILDING GROUND FLOOR EXEMPTION REQUESTED: 10CFR50 APPENDIX R, SECTION III.G.3.A PROBLEM: THE SEPARATION OF REDUNDANT TRAINS OF SAFE SHUTDOWN EQUIPMENT WITHIN THE FIRE ZONE DOES NOT MEET THE REQUIREMENTS OF 10CFR50 APPENDIX R, SECTION III.G.2.

DEDICATED SHUTDOWN CAPABILITY HAS BEEN PROVIDED FOR USE IN THE EVENT OF A FIRE IN THIS ZONE. THE FIRE AREA DOES NOT M.EET THE REQUIREMENTS OF SECTION III.G.3 OF APPENDIX R, IN THAT PARTIAL AREA FIRE DETECTION AND FIXED FIRE SUPPRESSION SYSTEMS ARE PROVIDED IN THE FIRE ZONE.

SONGS 1 SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION

SUMMARY

FOR FIRE ZONE 1-TB-35-9B TURBINE DECK EXEMPTION REQUESTED: 10CFR50 APPENDIX R, SECTION III.G.3.A PROBLEM: THE SEPARATION OF THE REDUNDANT TRAINS OF THE PRIMARY SYSTEM HOT LEG TEMPERATURE TRANSMITTERS WITHIN THE FIRE ZONE DOES NOT MEET THE REQUIREMENTS OF 10CFR50 APPENDIX R, SECTION III.G.2. ALTERNATIVE HOT LEG TEMPERATURE INDICATION IS AVAILABLE THROUGH THE USE OF THE PRIMARY SYSTEM DELTA T INSTRUMENTS IN THE CONTROL ROOM, OR THE HOT LEG TEMPERATURE INSTRUMENTS AT THE DEDICATED SHUTDOWN PANEL. THE FIRE ZONE DOES NOT MEET THE REQUIREMENTS OF SECTION III.G.3 OF APPENDIX R, IN THAT FIRE DETECTION AND FIXED FIRE SUPPRESSION SYSTEMS ARE NOT PROVIDED THROUGHOUT THE FIRE ZONE.

SONGS 1 SOUTHERN CALIFORNIA EDISON EXEMPTION

SUMMARY

FOR FIRE AREA 1-AB-20-2A REACTOR AUXILIARY BUILDING EXEMPTION REQUESTED: 10CFR50 APPENDIX R, SECTION III.G.3A PROBLEM: THE SEPARATION OF THE REDUNDANT CHARGING PUMPS AND THE CHARGING RWST ISOLATION VALVES WITHIN THE FIRE AREA DOES NOT MEET THE REQUIREMENTS OF 10CFR50 APPENDIX R, SECTION III.G.2. ALTERNATIVE SHUTDOWN CAPABILITY IS AVAILABLE THROUGH THE USE OF THE SAFETY INJECTION SYSTEM.

IN THE EVENT NORMAL CONTROL ROOM CONTROL OF CERTAIN VALVES IS IMPAIRED BY FIRE, OPERATOR ACTION WILL BE TAKEN TO MANUALLY CONTROL THESE VALVES, OR TO CONTROL MANUAL VALVES IN THE PROCESS LINE.

THIS FIRE AREA DOES NOT MEET THE REQUIREMENTS OF 10CFR50 APPENDIX R, SECTION Ill.G.3 IN THAT ONLY PARTIAL FIRE DETECTION AND FIXED SUPPRESSION IS PROVIDED IN THIS AREA.

SONGS-I SOUTHERN CALIFORNIA EDISON CO.

EXEMPTIONS SUBMITTED EXEMPTION REQUESTED FROM 10CFR50 APPENDIX R SECTION SAFE SHUTDOWN FIRE ZONE DESCRIPTION III.G.3a SCENARIO TO BE USED 1-AB-f1-34 PIPE TUNNEL S

ASO IMANUAL) 1-AB-20-2N FILTER ENCOSURE S

ASO (MANUAL)

DC SWITCH6EAR sAO(AUL 1-;PB-20-13 AND BATTERY ROOM S

AS (MANUAL)

I-PB-14-25 WEST CABLE SHAFT S

ASO (MANUAL) 1-PB-20-IIA HEALTH PHYSICS S

ASO (MANUAL)

SLOCKER ROOM 1-PB-20-12 OFFICES S

ASO (MANUAL)

I-YD-20-4C DOGHOUSE S

ASO (MANUAL) 1-YO-14-4F CONDENSATE STORAGE S

ASO (MANUAL)

TANK AREA MAIN TRANSFORMER I-TB-20-90 AREA S

ASO (MANUAL)

S = EXEMPTION SUBMITTED r r Cr r A fL C~r.,

f

SONGS 1 SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION

SUMMARY

FOR FIRE AREA 1-AB-11-34 PIPE TUNNEL EXEMPTION REQUESTED: 10CFR50 APPENDIX R, SECTION Ill.G.3A PROBLEM: IN THE EVENT NORMAL CONTROL ROOM CONTROL OF CERTAIN VALVES IS IMPAIRED BY FIRE, OPERATOR ACTION WILL BE TAKEN TO MANUALLY CONTROL THESE VALVES, OR TO CONTROL MANUAL VALVES IN THE PROCESS LINE. THIS FIRE AREA DOES NOT MEET THE REQUIREMENTS OF 10CFR50 APPENDIX R, SECTION 111.6.3 IN THAT FULL AREA FIRE DETECTION AND FIXED SUPPRESSION IS NOT PROVIDED IN THIS AREA.

SONGS 1 SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION

SUMMARY

FOR FIRE ZONE 1-AB-20-2N REACTOR COOLANT FILTER ENCLOSURE EXEMPTION REQUESTED: 10CFR50 APPENDIX R, SECTION III.G.3.A PROBLEM: IN THE EVENT NORMAL CONTROL ROOM CONTROL OF CERTAIN VALVES IS IMPAIRED BY FIRE, OPERATOR ACTION WILL BE TAKEN TO MANUALLY CONTROL THESE VALVES, OR TO CONTROL MANUAL VALVES IN THE PROCESS LINE. THIS FIRE ZONE.

DOES NOT MEET THE REQUIREMENTS OF 10CFR5O APPENDIX R, SECTION III.C.3 IN THAT FULL AREA FIRE DETECTION AND FIXED SUPPRESSION IS NOT PROVIDED IN THIS ZONE.

SONGS 1 SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION

SUMMARY

FOR FIRE AREA 1-PB-20-13 DC SWITCHGEAR AND BATTERY ROOM EXEMPTION REQUESTED:

10CFR50 APPENDIX R, SECTION III.G.3A PROBLEM:

IN THE EVENT NORMAL CONTROL ROOM CONTROL OF CERTAIN VALVES IS IMPAIRED BY FIRE, OPERATOR ACTION WILL BE TAKEN TO MANUALLY CONTROL THESE VALVES, OR TO CONTROL MANUAL VALVES IN THE PROCESS LINE. THIS FIRE AREA DOES NOT MEET THE REQUIREMENTS OF 10CFR50 APPENDIX R, SECTION III.G.3 IN THAT FULL AREA FIRE DETECTION AND FIXED SUPPRESSION IS NOT PROVIDED IN THIS AREA.

SONGS 1 SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION

SUMMARY

FOR FIRE AREA 1-PB-14-25 WEST CABLE SHAFT EXEMPTION REQUESTED: 10CFR50 APPENDIX R, SECTION III.G.3A PROBLEM: IN THE EVENT NORMAL CONTROL ROOM CONTROL OF CERTAIN VALVES IS IMPAIRED BY FIRE, OPERATOR ACTION WILL BE TAKEN TO MANUALLY CONTROL THESE VALVES, OR TO CONTROL MANUAL VALVES IN THE PROCESS LINE. THIS FIRE AREA DOES NOT MEET THE REQUIREMENTS OF 10CFR50 APPENDIX R, SECTION III.G.3 IN THAT FULL AREA FIRE DETECTION AND FIXED SUPPRESSION IS NOT PROVIDED IN THIS AREA.

SONGS 1 SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION

SUMMARY

FOR FIRE ZONE 1-PB-20-11A

.HEALTH PHYSICS AND LOCKER ROOM EXEMPTION REQUESTED: 10CFR50 APPENDIX R, SECTION III.G.3A PROBLEM: IN THE EVENT NORMAL CONTROL ROOM CONTROL OF CERTAIN VALVES IS IMPAIRED BY FIRE, OPERATOR ACTION WILL BE TAKEN TO MANUALLY CONTROL THESE VALVES, OR TO CONTROL MANUAL VALVES IN THE PROCESS LINE. THIS FIRE ZONE DOES NOT MEET THE REQUIREMENTS OF 10CFR50 APPENDIX R, SECTION III.G.3 IN THAT FULL AREA FIRE DETECTION AND FIXED SUPPRESSION IS NOT PROVIDED IN THIS ZONE.

SONGS I SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION SUMARY FOR FIRE AREA 1-PB-20-12 OFFICES EXEMPTION REQUESTED: 10CFR50 APPENDIX R, SECTION III.G.3A PROBLEM:

IN THE EVENT NORMAL CONTROL ROOM OF CERTAIN VALVES IS IMPAIRED BY FIRE, OPERATOR ACTION WILL BE TAKEN TO MANUALLY CONTROL THESE VALVES, OR TO CONTROL MANUAL VALVES IN THE PROCESS LINE. THIS FIRE AREA DOES NOT MEET THE REQUIREMENTS OF 10CFR50 APPENDIX R, SECTION Ill.G.3 IN THAT FULL AREA FIRE DETECTION AND FIXED SUPPRESSION IS NOT PROVIDED IN THIS AREA.

SONGS 1 SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION

SUMMARY

FOR FIRE ZONE 1-YD-20-4C DOGHOUSE EXEMPTION REQUESTED: 10CFR50 APPENDIX R, SECTION III.G.3.A PROBLEM: IN THE EVENT NORMAL CONTROL ROOM CONTROL OF CERTAIN VALVES IS IMPAIRED BY FIRE, OPERATOR ACTION WILL BE TAKEN TO MANUALLY CONTROL THESE VALVES, OR TO CONTROL MANUAL VALVES IN THE PROCESS LINE.

THIS FIRE ZONE DOES NOT MEET THE REQUIREMENTS OF 10CFR50 APPENDIX R, SECTION III.G.3 IN THAT FULL AREA FIRE DETECTION AND FIXED SUPPRESSION IS NOT PROVIDED IN THIS ZONE.

SONGS 1 SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION

SUMMARY

FOR FIRE ZONE 1-YD-14-4F CONDENSATE STORAGE TANK AREA EXEMPTION REQUESTED:

10CFR50 APPENDIX R, SECTION III.G.3.A PROBLEM: IN THE EVENT NORMAL CONTROL ROOM CONTROL OF CERTAIN VALVES IS IMPAIRED BY FIRE, OPERATOR ACTION WILL BE TAKEN TO MANUALLY CONTROL THESE VALVES, OR TO CONTROL MANUAL VALVES IN THE PROCESS LINE. THIS FIRE ZONE DOES NOT MEET THE REQUIREMENTS OF 10CFR50 APPENDIX R, SECTION III.G.3 IN THAT FULL AREA FIRE DETECTION AND FIXED SUPPRESSION IS NOT PROVIDED IN THIS ZONE.

SONGS I SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION

SUMMARY

FOR FIRE ZONE 1-TB-20-9D MAIN TRANSFORMER AREA EXEMPTION REQUESTED: 10CFR50 APPENDIX R, SECTION III.G.3.A PROBLEM: IN THE EVENT NORMAL CONTROL ROOM CONTROL OF CERTAIN VALVES IS IMPAIRED BY FIRE, OPERATOR ACTION WILL BE TAKEN TO MANUALLY CONTROL THESE VALVES, OR TO CONTROL MANUAL VALVES IN THE PROCESS LINE. THIS FIRE ZONE DOES NOT MEET THE REQUIREMENTS OF 10CFR50 APPENDIX R, SECTION III.6.3 IN THAT FULL AREA FIRE DETECTION AND FIXED SUPPRESSION IS NOT PROVIDED IN THIS ZONE.

SONGS-1 SOUTHERN CALIFORNIA EDISON CO.

EXEMPTIONS PENDING EXEMPTION REQUESTED FROM 10CFRS0 APPENDIX R SECTION SAFE SHUTDOWN FIRE AREA DESCRIPTION III.G.2a III.G.2b III.G.3a SCENARIO TO BE USED 1-CO-(-10)-1 CONTAINMENT P

P OSS 1-AB-11-34 PIPE TUNNEL P

ASO 1-FH-14-7 480 V SWITCHGEAR P

ASO I-PB-20-13 ADC SWITCH6EAR P

ASD 1-PB-0-13 AND BATTERY ROOMAS

-PB-14-25 WEST CABLE SHAFT P

ASO

-PB-56-33 CONTROL BLOCK ROOF P

ASO

-PB-20-12 OFFICES P

ASO

= EXEMPTION PENDING

'c:r.r~ A i if i

,r

SONGS 1 SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION

SUMMARY

FOR FIRE AREA I-CO-(-1O)-1 CONTAINMENT EXEMPTION REQUESTED:

iOCFR5O APPENDIX R. SECTION III.G.2.D AND III.G.3.A PROBLEM:

THE SEPARATION OF THE REDUNDANT RCS TEMPERATURE.

PRESSURIZER LEVEL AND PRESSURE AND STEAM GENERATOR LEVEL INSTRUMENTS, PRESSURIZER HEATERS AND ASSOCIATED CABLES DOES NOT MEET THE REQUIREMENTS OF iOCFR5O APPENDIX R, SECTION III.G.2.D. DEDICATED SHUTDOWN CAPABILITY IS PROVIDED. CABLES FOR THE DEDICATED SHUTDOWN SYSTEM COMPONENTS, WHICH ARE LOCATED WITHIN THE FIRE AREA. ARE ONE HOUR FIRE RATED, AND ARE ROUTED IN NEW CONDUIT. THE FIRE AREA DOES NOT MEET THE REQUIREMENTS OF SECTION III.G.3 OF APPENDIX R. IN THAT THE INSTRUMENTS PROVIDING INDICATION AT THE DEDICATED SHUTDOWN PANEL, AND THE DEDICATED SHUTDOWN PRESSURIZER HEATER CABLES AT THE PRESSURIZER, ARE NOT INDEPENDENT OF THE FIRE AREA. AND PARTIAL AREA FIRE DETECTION AND PARTIAL AREA FIXED SUPPRESSION SYSTEMS ARE PROVIDED IN THE FIRE AREA.

FIRE AREA THE CONTAINMENT IS STEEL SPHERE. A STEEL DESCRIPTION:

PERSONNEL HATCH AND AN EQUIPMENT HATCH COMMUNICATE WITH I-TB-35-98. A SECOND PERSONNEL HATCH OPENS TO 1-YD-14-4D. ELECTRICAL AND MECHANICAL PENETRATIONS ARE DESIGNED TO PREVENT THE RELEASE OF RADIOACTIVE PRODUCTS BUT ARE NOT FIRE RATED.

EXEMPTION

SUMMARY

FOR FIRE AREA I-CO-(-10)-1 CONTAINMENT (PAGE 2)

FIRE PROTECTION IONIZATION SMOKE DETECTORS PROVIDED IN FEATURES PROVIDED:

ELECTRICAL PENETRATION AREA OVER STEAM GENERATORS AND RCPS AND UNDER THE PRESSURIZER. INFRARED FLAME DETECTORS ARE LOCATED ON CRANE RAILS ABOVE OPERATING FLOOR AND IN RHR PUMP AREA. MANUAL CONNECTIONS FROM THE FIRE MAIN TO SUPPRESSION SYSTEMS AT THE RCPS, RHR PUMPS AND HOSE STATIONS WILL BE PROVIDED WHEN DSS IS USED. CONTAINMENT SPRAY SYSTEM CAN BE USED FOR FIRE SUPPRESSION AND PORTABLE EXTINGUISHERS ARE LOCATED WITHIN THE CONTAINMENT.

COMBUSTIBLE LOADING:

23.800 BTUlSo.FT. FOR A DURATION OF 18 MINUTES.

CONSISTING OF CABLE TRAYS.

SAFE SHUTDOWN RCS TEMPERATURE, PRESSURIZER PRESSURE AND EQUIPMENT OF CONCERN:

LEVEL AND STEAM GENERATOR LEVEL INSTRUMENTATIONS AND CABLES. PRESSURIZER HEATER CABLES.

BASIS OF EXEMPTION:

DEDICATED SHUTDOWN SYSTEM CABLES ARE ONE HOUR RATED (ROCKBESTOS CABELS) ROUTED IN NEW CONDUIT.

RCPs PROVIDED WITH OIL COLLECTION SYSTEM MEETING III.0 REQUIREMENTS.

CHARCOAL CONTRAINED ENTIRELY WITHIN HVAC UNITS.

DEDICATED SHUTDOWN INSTRUMENTS LOCATED IN CABINETS (3/16" STEEL WALL AND 2" OF FIBERGLASS) SEPARATE FORM REDUNDANT INSTRUMENTATION.

PORV AND BLOCK VALVE SOLENOIDS PROTECTED BY HEAT SHEI'o.

SHUTDOWN CAN BE ACCOMPLISHED WITH ONLY ONE STEAM GENERATOR.

EXISTING DETECTION AND SUPPRESSION CAPABILITY PROTECTS AREAS OF CONCERN.

EXEMPTION

SUMMARY

FOR FIRE AREA I-CO-(-10)-1 CONTAINMENT (PAGE 3)

BASIS OF EXEMPTION:

TRANSIENT COMPBUSTIBLES STRICTLY CONTROLLED IN (CONTINUED)

CONTAINMENT.

RCS TEMPERATURE AND STEAM GENERATOR LEVEL INSTRUMENTS ARE SPATIALLY SEPARATED.

CHARCOAL IS CONTAINED WITHIN METAL HOUSING OF THE HVAC UNITS

SONGS-1 Southern California Edison Co.

45~~~~o ICE.IS->

PTH CUR 425 CAB. #4 LTO

%U TE DSS E

LT Sp, 4128 EL 451C EL.I eo.OmTE S

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412AI s-1 J-REACTO VESSEL PT C-1 425T SS S

432 1 14028 1

E IOl-l LT~~SR PRSUIZR1 431~~T SSIE O

PT PRSSURIER SS 4-1; L. I 66 LT S4 PET0 ATNTPIMENTS 30 34 6-g48 402 EL.0-O LT-S' ELT ORESUIUREHAT 4~~PD IT 0

PIC O

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PRSSRIE C-2NTOA-2 VETI.T PTIP PO LT S

34 coNd i ET 30k SFjltWE EL.20'-0*

SSJ1J JWI

SONGS I SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION

SUMMARY

FOR FIRE AREA i-FH-14-7 480V SWITCHGEAR EXEMPTION REQUESTED:

10CFR5O APPENDIX R. SECTION III.G.2.A PROBLEM:

ALTERNATE SHUTDOWN IS CREDITED FOR A FIRE IN THIS AREA DUE TO MANUAL ACTIONS.

UNSEALED DUCT IN THE SOUTH WALL ADJOINING i-TB-35-9B DOES NOT HAVE A 3-HOUR RATING.

ONE HOUR RATED WALLS ON THE EAST AND SOUTH SIDES ADJOINING I-TB-8-9A.

FIRE AREA THE NORTH WALL OF THE AREA IS 3 HOUR RATED. THE WEST DESCRIPTION:

WALL AND THE SOUTH WALL ADJOINING 1-YD-20-4D ARE i-HOUR RATED CONCRETE BLOCK CONSTRUCTION. THE EAST WALL AND THE SOUTH WALL ADJOINING ZONE i-TB-8-9A ARE PROVIDED WITH A DIRECTED AUTOMATIC WET PIPE SPRINKLER SYSTEM. THE CEILING IS 3-HOUR RATED REINFORCED CONCRETE CONSTRUCTION. TWO 3-HOUR RATED DOORS SEPARATE THE AREA FROM 1-YD-20-4D. THE AREA COMMUNICATES WITH THE GROUND FLOOR OF i-TB-8-9A THROUGH A 3-HOUR RATED DOOR. ALL VENTILATION DUCT PENETRATIONS ARE PROVIDED WITH 3-HOUR RATED FIRE DAMPERS EXCEPT THE DUCT THROUGH THE SOUTH WALL TO I-TB-35-9B.

THIS DUCT IS APPROXIMATELY 8'O-"

WIDE AND 2'-6" HIGH AND IS LOCATED NEAR THE CEILING AT THE EAST END OF THE ROOM.

FIRE PROTECTION AREA WIDE IONIZATION SMOKE DETECTORS. TOTAL FLOODING

EXEMPTION

SUMMARY

FOR FIRE AREA 1-FH-1-7 480V SWITCHGEAR (PAGE 2)

FEATURES PROVIDED:

HALON 1301 FIRE EXTINGUISHING SYSTEM WITH MAIN AND RESERVE CYLINDERS.

COMBUSTIBLE LOADING:

137.190 BTUs/so. FT. FOR A DURATION OF 1.71 HOURS. COMBUSTIBLES ARE DISTRIBUTED THROUGHOUT THE AREA.

SAFE SHUTDOWN CIRCUITS ASSOCIATED WITH THE 480V ELECTRICAL EQUIPMENT OF CONCERN:

DISTRIBUTION SYSTEM. CVCS. RCS. CCW. SWC. CVS.

RHR AND SIS.

BASIS FOR EXEMPTION:

HALON 1301 FIRE EXTINGUISHING SYSTEM IS AVAILABLE.

FIRE PROTECTION FEATURES FOR THIS AREA WERE PREVIOUSLY APPROVED BY NRC IN REVIEW OF APPENDIX A.

PROMPT RESPONSE BY ONSITE FIRE DEPARTMENT.

MANUAL OPERATOR ACTION WILL BE TAKEN OUTSIDE THIS FIRE AREA TO POSITION AUXILIARY FEEDWATER CONTROL VALVE, START CCW PUMP, OPEN RHR VALVES AND CLOSE RCS VENT VALVES.

PENDING MODIFICATION TO PROVIDE CHARGING PUMP SUCTION BYPASS LINE TO PRECLUDE CAVITATION OF THE CHARGING PUMPS.

CIRCUITS FOR SWC PUMP G-13A WILL BE REROUTED OUTSIDE THIS FIRE AREA.

SIMILAR FIRE AREA/

1-PB-14-25 ZONES WHERE THIS TYPE 1-AB-11-34 OF EXEMPTION MAY BE 1-AB-(-3)-2A REQUIRED:

SONGS I SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION

SUMMARY

FOR FIRE ZONE I-PB-20-IIA AND I-PB-20-12 HEALTH PHYSICS & LOCKER ROOMIOFFICES EXEMPTION REQUESTED:

10CFR5O APPENDIX R. SECTION III.G.2.A PROBLEM:

SAFE SHUTDOWN EQUIPMENT IN THESE FIRE ZONES, IS NOT SEPARATED FROM REDUNDANT SAFE SHUTDOWN EQUIPMENT BY 3-HOUR BARRIERS.

FIRE ZONE THE ALLS SEPARATING THE AREA/ZONE FROM I-Pa-14-8 ARE DESCRIPTION:

3-HOUR RATED. THE WALLS ON THE WEST SIDE ARE REINFORCED CONCRETE. THE EAST WALL OF THE AREA/ZONE IS GLASS AND CONCRETE BLOCK. THE SOUTH WALL IS i-HOUR RATED. THE NORTH WALL IS 8" THICK REINFORCED CONCRETE IN THE OFFICE AREA AND 13" THICK REINFORCED CONCRETE IN THE LOCKER AREA. THE CEILING OF THE AREA/ZONE IS REINFORCED CONCRETE.

EAST WALL HAS A NONRATED DOOR TO THE EXTERIOR. SEVERAL LARGE DUCT PENETRATIONS PROVIDE COMMUNICATION TO THE EXTERIOR. A NONRATED DOOR ALLOWS ACCESS FROM THE DUMBWAITER SHAFT INTO I-P8-42-30B.

UNSEALED CONDUIT AND PIPING PENETRATIONS COMMUNICATE WITH I-PB-32-11B.

FIRE PROTECTION IONIZATION SMOKE DETECTORS ARE INSTALLED IN THE FEATURES PROVIDED:

CORRIDOR OF 1-PB-20-i1A. IONIZATION SMOKE DETECTORS PROVIDING PARTIAL AREA COVERAGE ARE INSTALLED IN i-PB-20-12. HOSE STATIONS AND PORTABLE EXTINGUISHERS ARE PROVIDED.

COMBUSTIBLE LOADING:

35.486 BTulSo. FT. FOR A DURATION OF 27 MINUTES.

COMBUSTIBLES ARE DISTRIRUJTED THROUGHOUT THE AREA.

EXEMPTION

SUMMARY

FOR FIRE ZONE I-PB-20-1IA I-PB-20-12 HEALTH PHYSICS & LOCKER ROOM/OFFICES (PAGE 2)

SAFE SHUTDOWN SAFE SHUTDOWN EQUIPMENT FOR THE ESSENTIAL ELECTRICAL EQUIPMENT:

SYSTEM. MAIN STEAM SYSTEM AND COMPONENT COOLING WATER SYSTEM ARE LOCATED IN THIS AREA/ZONE.

BASIS FOR EXEMPTION:

THERE IS NO EXPOSURE EAST OF FIRE AREA i-PB-20-12.

DUMBWAITER SHAFT PROVIDES A TORTUOUS PATH FOR PROPAGATION WITH MINIMAL COMBUSTIBLES IN VICINITY.

IONIZATION DETECTORS PROVIDE EARLY WARNING FOR PROMPT RESPONSE BY ONSITE FIRE DEPARTMENT.

OPERATOR ACTION CREDITED FOR CLOSE MANUAL VALVE UPSTREAM OF FCV-1112 IF CHARGING THROUGH SEAL INJECTION FLOW PATH IS REQUIRED.

TURBINE TRIP AT TURBINE STAND SIMILAR FIRE AREA/

I-P3-20-13 ZONES WHERE THIS TYPE OF EXEMPTION MAY BE REQUIRED:

SONGS-I SOUTHERN CALIFORNIA EDISON CO.

EXEMPTIONS PENDING EXEMPTION REQUESTED FROM 10CFR5O APPENDIX R SECTION SAFE SHUTDOWN

'IRE AREA DESCRIPTION III.G.2a III.G.2b SCENARIO TO BE USED AB-(-32A REACTOR AUXILIARY P

ASO BLDG. LOWER LEVEL

-YD-20-4A EAST PENETRATION P

DSS WEST PENETRATION P

DSS

-YD-20-4B AREA i-YD-14-4F CONDENSATE STORAGE P

ASO TANK AREA

-PB-20-11A HEALTH PHYSICS P

ASO ILOCKER ROOM

-TS89A TURBINE BLDG*

P OSS GROUND FLOOR

-TB-35-98 TURBINE DECK P

ASO 1-TH-20-90 MAIN TRANSFORMER P

ASO i-TB-0-90AREA P = EXEMPTION PENDING SEUDPAPH't1 t4 /SGr

SONGS 1 SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION

SUMMARY

FOR FIRE ZONE i-YD-20-4B WEST PENETRATION AREA EXEMPTION REQUESTED:

10CFR50 APPENDIX R. SECTION III.G.2.B PROBLEM:

DEDICATED SHUTDOWN SYSTEM OPERATION IS CREDITED FOR A FIRE IN THIS FIRE ZONE. DSS CIRCUITS ARE ROUTED THROUGH THIS ZONE. THE SEPARATION OF THIS ZONE FROM ADJOINING AREA/ZONES CONTAINING DEDICATED SHUTDOWN SYSTEM EQUIPMENT AND CABLE IS GREATER THAN 20 FT. WITH INTERVENING COMBUSTIBLES.

AUTOMATIC SUPPRESSION SYSTEM IS NOT PROVIDED. LOCALIZED DETECTON IS PROVIDED.

FIRE ZONE EXTERIOR FIRE ZONE, BOUNDED BY THE STEEL CONTAINMENT DESCRIPTION:

SPHERE, ENCLOSURE BUILDING, FUEL HANDLING BUILDING AND TURBINE BUILDING. THE WALL WHICH SEPARATES THE ZONE FROM I-TB-8-9A IS A 1-HOUR RATED WALL PROVIDED WITH AUTOMATIC WET PIPE SPRINKLERS IN 1-TB-8-9A THUS MAKING IT 3 HOUR EQUIVALENT. THE WALL AD3OINING 1-FH-(-2)-5 IS REINFORCED CONCRETE. THE ENCLOSURE BUILDING WALL IS CONCRETE.

TWO 3-HOUR RATED DOORS AND A BARRED NONRATED DOOR OPEN TO 1-YD-14-4D.

TWO NONRATED DOORS COMMUNICATE WITH i-VN-20-24.

THE ZONE IS OPEN TO 1-YD-20-4A WHERE THE TWO ZONES MEET ON BOTH SIDES OF THE CONTAINMENT SPHERE. TO 1-YD-14-4D AT THE NORTHWEST AND SOUTHEAST CORNERS OF 1-VN-20-24. TWO DUCT PENETRATIONS (3' DIAMETER AND 5' x 6'). 4 CONDUIT PENETRATIONS (6" DIAMETER) AND ONE PIPING PENETRATION (3-1/2" DIAMETER) COMMUNICATE WITH 1-YD-14-4D.

FIRE PROTECTION IONIZATION SMOKE. ULTRAVIOLET FLAME AND HEAT DETECTORS FEATURES PROVIDED:

PROVIDE LOCALIZED PROTECTION FOR THE MAJOR EQUIPMENT 71 THE 7CINE.

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EXEMPTION

SUMMARY

FOR FIRE ZONE 1-YD-20-4B WEST PENETRATION AREA (PAGE 2)

COMBUSTIBLE LOADING:

23.491 BTU/SO. FT. FOR A DURATION OF 18 MINUTES.

PRIMARILY CABLE INSULATION. HEALTH PHYSICS STORAGE SHED. CONTAINING PLASTIC, WILL BE REMOVED.

SAFE SHUTDOWN EQUIPMENT OF CONCERN:

DEDICATED SAFE SHUTDOWN EQUIPMENT AND CABLE IS LOCATED IN ADJACENT ZONES.

BASIS FOR EXEMPTION:

LOW FIRE LOADING.

INSUFFICIENT COMBUSTIBLE LOADING EXISTS ON BOTH SIDES OF OPENINGS AND PENETRATIONS TO PROPAGATE A FIRE.

CABLE TRAYS ROUTED BETWEEN THE.FUEL HANDLING BUILDING AND VENTILATION BUILDING THROUGH WALKWAY TO 1-YD-14-4D WILL BE PROVIDED WITH FIRE STOPS AND WILL BE PROTECTED BY A SUPPRESSION SYSTEM.

EXISTING DETECTION SYSTEMS PROVIDE EARLY WARNING IN THE CONTROL ROOM FOR PROMPT ONSITE FIRE DEPARTMENT RESPONSE.

DEDICATED SHUTDOWN EQUIPMENT IN ZONE 1-YD-14-48 ARE WRAPPED WITH 3-HOUR BARRIER.

SEPARATION OF THE DEDICATED SHUTDOWN SYSTEM EQUIPMENT IN ADJACENT FIRE ZONES IS GREATER THAN 20 FT. WITH LIMITED INTERVENING COMBUSTIBLES FROM OPENINGS IN FIRE ZONE 1-YD-20-48.

SIMILAR FIRE AREA/

i-YD-20-4A ZONES WHERE THIS TYPE 1-TB-8-9A OF EXEMPTION MAY BE REQUIRED:

SONGS 1 SOUTHERN CALIFORNIA EDISON COMPANY EXEMPTION

SUMMARY

FOR FIRE AREA 1-YD-14-4F CONDENSATE STORAGE TANK AREA EXEMPTION REQUESTED:

IOCFR50 APPENDIX R. SECTION III.G.2.B PROBLEM:

SEPARATION OF THIS FIRE ZONE FROM REDUNDANT SAFE SHUTDOWN EQUIPMENT IN THE ADJACENT FIRE ZONES IS GREATER THAN 20 FT. WITH INTERVENING COMBUSTIBLES.

FIRE ZONE THE NORTH AND EAST BOUNDARIES OF THE CONDENSATE DESCRIPTION:

STORAGE TANK AREA IS SEPARATED FROM i-TB-8-9A BY CONCRETE BLOCK WALLS. THE SOUTH AND WEST BOUNDARIES ARE IDENTIFIED BY THE VITAL AREA FENCE.

A FOUR INCH GAP. FLASHED WITH SHEET METAL, RUNS ALONG THE ENTIRE LENGTH OF THE NORTH AND EAST WALLS ABOVE THE CONCRETE BLOCK WALLS. A 1-112 HOUR RATED DOOR AND A NONRATED DOOR PROVIDE ACCESS TO 1-T3-8-9A. A 30' X 5' LOUVERED OPENING IN THE EAST WALL. (20 FT. ABOVE GROUND LEVEL) AND SEVERAL UNSEALED PIPING AND CONDUIT PENETRATIONS RANGING IN SIZE FROM 1* TO 10" DIAMETER ALSO COMMUNICATE WITH I-TS-8-9A.

FIRE PROTECTION PORTABLE EXTINGUISHERS AND HOSE STATIONS ARE PROVIDED FEATURES:

IN THE AREA.

COMBUSTIBLE LOADING:

371.954 BTulSo. FT. FOR A DURATION OF 4.65 HOURS.

CONSISTING OF OIL. HYDROGEN IN TANKS AND CABLE INSULATION WIDELY SEPARATED WITHIN THE ZONE.

SAFE SHUTDOWN CABLES FOR RWST CHARGING ISOLATION VALVE, MOV-1100D EQUIPMENT OF 4160V BUSES AND MCC 3 CONCERN:

EXEMPTION

SUMMARY

FOR FIRE AREA 1-YD-14-4F CONDENSATE STORAGE TANK AREA (PAGE 2)

BASIS FOR EXEMPTION:

THE FIRE ZONE IS AN OUTSIDE AREA WITH NO SIGNIFICANT INTERVENING COMBUSTIBLES BETWEEN THE AREAS OF COMBUSTIBLE CONCENTRATION.

THE HYDROGEN ENCLOSED IN CYLINDERS IS NOT EASILY IGNITED.

COMBUSTIBLE CONCENTRATIONS ARE GREATER THAN 20 FT.

FROM OPENINGS TO I-TB-8-9A.

A FIRE WILL BE READILY DETECTED BY PLANT PERSONNEL DUE TO THE OPEN CONFIGURATION OF THE ZONE THEREBY ALLOWING PROMPT ONSITE FIRE DEPARTMENT RESPONSE USING AVAILABLE MANUAL FIRE SUPPRESSION EQUIPMENT.

MANUAL OPERATOR ACTION IS CREDITED FOR:

DG 1 POWER TO 4160V BUS iC DG 2 POWER TO 4160V Bus 2C ISOLATION OF THE VOLUME CONTROL TANK ISOLATION VALVE MOV-1100C THE CIRCUIT FOR MOV-883 IS ROUTED AT THE NORTH END OF 1-YD-14-4F OPERATOR ACTION MAY BE REQUIRED TO DENERGIZE AND OPEN MOV-883 LOCATED IN 1-YD-14-4D.

REDUNDANT RWST CHARGING ISOLATION VALVE, MOV-11008. WILL REMAIN AVAILABLE BECAUSE ITS CIRCUITS ARE ROUTED OVER 100 FEET FROM 1-YD-14-4F. A FIRE WOULD HAVE TO TAKE A TORTUROUS PATH THROUGH THE PENETRATIONS ONTO CABLE TRAYS IN I-TB-8-9A AND PROPAGATE OVER 100 FEET TO EFFECT THE CIRCUITS FOR MOV-1100B.

SIMILAR FIRE AREA/

I-P8-56-33 ZONES WHERE THIS TYPE I-T3-35-98 OF EXEMPTION MAY BE 1-T8-20-9D REQUIRED:

SONGS-I SOUTHERN CALIFORNIA EDISON CO.

DEVIATIONS FROM NRC GUIDANCE FIRE AREA GUIDANCE REFERENCE DEVIATION 1-PB-42-16 GENERIC LETTER 85-01 CREDIT FOR TRIPPING OFFSITE SECTION 3.8.4, POWER BREAKERS IN ADDITION OCONTROL ROOM FIRE TO REACTOR TRIP IS BEING CONSIDERATIONSO REQUESTED.

VARIOUS IE INFORMATION NOTICE LOCAL MANUAL SAMPLING WILL NO.84-09, ATTACHMENT 1 BE MADE TO DETERMINE REACTIVITY SECTION IX IN FIRE AREAS/ZONES WHERE OINSTRUMENTATION REQUIRED REDUNDANT SOURCE RANGE FOR ALTERNATIVE SHUTDOWN' MONITORS MAY BE LOST DUE TO THE EFFECTS OF A FIRE.