ML20080G288

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RO Re Fire Protection Cable Separation Criteria.Intent of License Condition 2.G Discussed W/Nrr & Util Submitted Request for License Amend to Revise Reporting Requirements
ML20080G288
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 01/26/1984
From: Haynes J
SOUTHERN CALIFORNIA EDISON CO.
To: Martin J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
NUDOCS 8402130333
Download: ML20080G288 (2)


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HECElWD tmc Southern California Edison Company SW S AN ONOFRE NUCLE AR GENER A TING ST A TION p.o.som12e S AN CLEMENTE C ALIPCRNI A 92672 January 26, 1984 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region V 1450 Maria Lane, suite 210 Walnut Creek, California 94596-5368 Attention:

Mr. J. B. Martin, Regional Administrator

Dear Sir:

Subject:

Docket Nos. 50-361 and-50-362 14-Day Follow-Up Report License Conditions 2.C.(14)a and 2.C.(12)a San Onofre Nuclear Generating Station, Units 2 and 3

Reference:

Letter,_J. G. Haynes (SCE) to J. B. Martin (NRC),

dated January 13, 1984 The referenced letter provided you with confirmation of our prompt notification of a_ reportable occurrence involving fire protection cable separation criteria.

Pursuant to License Condition 2.G to Facility Operating' Licenses NPF-10 and NPF-15 for San Onofre Units

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2 and 3, respectively, this submittal provides the required 14-Day 7

Follow-Up Report.

License Conditions 2.C.(14)a and 2.C.(12)a for Units 2 and 3, respectively, require that SCE maintain in effect and fully implement the Fire Protection Plan as delineated in the Fire Hazards Analysis (FHA).

As indicated in the referenced letter, during a review of Nonconformance Reports (NCR's), it was determined that 23 NCR's identifying cable tray wraps, UHF cable wraps, fire rated wall seismic joints, and a spray / sprinkler i

system, apparently are not in full compliance with the FHA.

Our continuing review has identified a substantial number of additional NCR's which we are currently evaluating relative to requirements of the FHA.

Some of these NCR's resulted from our effort to verify and update the FHA'as discussed below.

Further, 8402130333 840126

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Mr. J. B. Martin January 26, 1984 these NCR's identify additional examples of the conditions reported in the~ referenced letter.

In accordance with 10 CPR 50.73(a)(2)(ii)(B), we will submit a Licensee Event Report (84-001, Docket No. 50-361) on February 10, 1984, addressing all deficiencies identified by the NCR's.

Compensatory measures required by the Technical Specifications have been established.

However, with respect to the Technical Specification 3.7.8.2 requirements to provide a continuous fire watch in the Salt Water Cooling Tunnel as a result of the absence of a spray / sprinkler system in that area, we plan to rely on the operable fire detection system in that area as the compensatory fire watch.

An alarm of this detection system will result in prompt response of on shift fire protection personnel.

This plan is based on personnel safety considerations since the Salt Water Cooling Tunnel is a confined space.

As has been discussed with members of your staff, SCE has i

proceeded with efforts to verify that the as-built configuration of San Onofre Units 2'and 3 is consistent with the FHA and initiated efforts to update the FHA early in 1983.

The revised FHA is now scheduled to be completed and submitted to the NRC by mid-February 1984.

SCC believes that it is not the intent of License Condition 2.G to require the reporting of such incidents.

The intent of License Condition 2.G has been discussed with NRR and, as a result, SCE has submitted a request for license amendment to revise the current reporting requirements of the License Condition.

If you' require any additional information or disagree with our plan to utilize an operable fire detection system as a fire watch in the Salt Water Cooling Tunnel, please so advise.

Sincer ly, C/N G 4415----

cc:

A. E. Chaffee (USNRC Resident Inspector, Units 1, 2 and 3)

J. P. Stewart (USNRC Resident Inspector, Units 2 and 3)

U. S. Nuclear Regulatory Commission

Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Division of' Technical Information and Document Control

. Institute of Nuclear Power Operations (INPO)

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