ML20077B062
| ML20077B062 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/22/1994 |
| From: | Marsh W SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEIN-89-052, IEIN-89-52, NUDOCS 9411280239 | |
| Download: ML20077B062 (2) | |
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Southem Califomia Edison Company 23 PARKER STREET 1RVINE, CALIFORNIA 92718 November 22, 1994 m,_
WALTER C. MARSH mn.orn o, nucmn n.am.ro-n.
< mi.s mm U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C.
20555 Gentlemen:
Subject:
Docket Nos. 50-361 and 50-362 Resolution of Operational Concerns Identified in NRC Information Notice 89-52 San Onofre Nuclear Generating Station Units 2 and 3 As requested by the NRC staff during a telephone conference call on September 12, 1994, this letter provides Edison's understanding of 10 CFR 50 Appendix R, Section III.J emergency lighting requirements. The conversation (Mel Fields /NRC, Amarjit Singh/NRC, Steve West /NRC, Scott Medling/ Edison, et al) was to discuss Edison's approach to fire damper operational concerns identified in NRC Information Notice 89-52, " Potential Fire Damper Operational Problems."
Edison has determined that deenergizing the HVAC units is the most i
expeditious and cost effective means of resolving the concerns identified in Information Notice 89-52.
Deenergizing the HVAC units will eliminate the air flow through the subject fire dampers. This, along with the in-service testing -
and inspection program, will provide increased assurance of fire damper closure capability in the event of a fire.
Edison plans to deenergize specified HVAC units by performing specific manual operator actions at the respective breaker locations. Information Notice 89-52 identifies these manual actions to HVAC units as an acceptable approach for resolving damper closure Concerns.
During the conference call, an examination of the requirements of Appendix R was performed. When asked by the staff, Edison stated that these dampers and associated HVAC units have no direct safe shutdown function.
The-staff then-noted that the emergency lighting requirements of Appendix R therefore would not apply. Since the damper issue involves the integrity of fire barriers exclusively, the issue should be evaluated with respect to Generic Letter 86-10, " Implementation of Fire Protection Requirements."
Consistent with this understanding, Edison intends to use Generic Letter 86-10 for guidance in the final resolution of the fire damper operational concerns identified in Information Notice 89-52. A feasibility evaluation for manual actions needed to support the Information Notice 89-52 resolution will be included in a revision to our existing fire damper study. Feasibility evaluations for manual actions will include consideration of safe shutdown functional requirements, operator time and manpower requirements, and the adequacy of emergency lighting provisions.
The fire damper study will be available for future inspection activities.
9411280239 941122 hh PDR ADOCK 05000361 UV I h O
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',f"[2 -5 Document Control Desk If you have any questions on the above or if you require additional information, please contact me.
Very truly yours,
$ 0l cc:
L. J. Callan, Regional Administrator, NRC Region IV A. B. Beach, Director, Division of Reactor Projects, Region IV K. E. Perkins, Jr., Director, Walnut Creek Field Office, NRC Region IV J. A. Sloan, NRC Senior Resident Inspector, San Onofre Units 2 & 3 M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3