ML20136D969
| ML20136D969 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/11/1980 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20136D968 | List: |
| References | |
| FOIA-85-425 NUDOCS 8011260455 | |
| Download: ML20136D969 (6) | |
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l ENCLOSURE 1 i
CHEMICAL ENGINEERING BRANCH / FIRE PROTECTION SECTION ADDITIONAL FIRE PROTECTION INFORMATION REVIEW SAN ON0FRE NUCLEAR GENERATING STATION DOCKET h0. 50-206 FIRE DETECTION SYSTEMS, SECTION 3.1.l(5)
In the SER, it.was our concern that the fire detection system in the turbine lube oil reservoir area of the turbine building may not be adequate to detect a fire in this area.
By letter dated September 26, 1980, the licensee provided additional infor.
mation regarding their fire detection system protecting the lube oil reservoir and conditioner area. The lube oil reservoir and conditioner are enclosed by a four foot high wall. The licensee has installed infra-red flame detectors and line-type heat detectors in this dyked area. The installation of the six infra-red flame detectors provides the capability for line-of-sight surveillance over the entire area enclosed by the dyke. Also, the installa-tion meets all of the recomendations of NFPA 72E, Chapter 5,
" Flame Sensing Fire Detectors".
The fire detection system which the licensee has installed would be adequate to detect either a. fire originating in the cable trays or an exposure fire in the lube oil reservoir and conditioner area.
In addition to the flame detectors and line type heat detectors, the existing system of ionization smoke detectors located in this area was left intact. This provides additional detection capability for this area.
Based on our review, we conclude that the fire detection system for the turbine lube oil reservoir and conditioner area, which is installed in accordance with NFPA 72E, meets Section C.5(a)(3) of BTP APCSB 9.5-1 and, therefore, is accept-able.
FIRE PUMP TEST FEATURES, SECTION 3.1.2(a)
In the SER, it was our concern that the test method conducted to verify the fire pump curves may not be adequate since they do not meet the recomenda-tions of NFPA 20.
By letter dated January 23, 1980, the licensee provided information to show the test method used at their plant complies with NFPA 20. We informed the licensee that the use of a 2-inch valve on a 8-inch pump header to relieve the pressure to the pressure actuated control switch as a means of testing the control setpoints of the fire pumps does not allow for sufficient accuracy in determining the pressure setpoints and does not meet the recomendations of NFPA 20. Additionally, we informed the licensee that the use of the 480 volt switchgear as a pump controller is not in compliance with NFPA 20, since it is not a UL listed controller.
By letter dated September.26, 1980, the licensee proposed to install a 1/2-inch line with 1/2-inch check valves.which meets the recomendations of Appendix A to NFPA 20. The licensee also verified that the switchgear breaker used as a controller meets the requirements for VL listed controllers.
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. Based on the licensee's proposed modifications, we conclude that the test features for the fire pumps will meet the recommendations of NFPA 20 and, therefore, are acceptable.
INSULATION VALVE IN YARD LOOP TORUS CONNECTION, SECTION 3.1.2(b)
In the SER, the concern was that isolation valves were not provided in the above ground cross connection of the yard loop which is routed through the turbine building to prevent the loss of both manual and automatic water suppression system due to a single impairment.
By letter dated September 26, 1980, the licensee provided additional infor-mation concerning their design of the manual and automatic capability for fire suppression within the. lube oil area. The licensee modified the system by installing isolation valve BV-1 to provide manual and automatic fire suppression capability in the lube oil area.
Based on our review, we find that a single isolation valve to the turbine building cross connection does not adequately isolate the automatic sup-pression systems and the standpipe stations in the turbine building.
Isolation valve BV-1 only isolates the automatic suppression system and manual standpipe system for the lube oil area.
To meet Section III.B of Appendix R to 10 CFR 50, the licensee should provide additional valves in the yard loop cross connection through the turbine building so that a single break will not simultaneously impair any standpipe hose stations and an automatic suppression system.
NORTH TURBINE BUILDING AREA, CABLE WATER SPRAY SYSTEM, SECTION 3.1.5(b)
In the SER, it was our concern that the fire protection provided for the cable trays in the north turbine building area was not adequate. We recommended that a sectionalized directed water spray system be provided, in addition to already existing systems. We also recommended that actuation of the system be provided by use of line-type temperature detectors placed in the cable trays.
In the letter dated January 23, 1980, the licensee provided the drawings of their proposed cable tray water spray deluge system. Additionally, the licensee stated that a line type heat detection system is located in the cable trays and used to actuate the deluge system. We informed the licensee that the system be designed to provide a water spray density of at least 0.15 gpm/ft.2 We also recommended that the licensee provide three water spray deluge systems.
By letter dated September 26, 1980, the licensee erified that the design density of the water spray systems is 0.15 gpm/ft. Additionally, the licensee verified that the cable trays in the area are divided into three sections with a separate water spray and deluge valve, with manual actuation capability for each section.
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, The licensee's water spray design density is in accordance with the recommendations of NFPA 15 and, therefore, acceptable. The licensee has sectionalized the cable tray water spray deluge systems such that each section can operate independently of the other which meets our recomenda-tions and, therefore, is acceptable.
WATER SUPPRESSION SYSTEM, SECTION 3.1.5(d)
In the SER, we were concerned that the licensee had not provided adequate fire protection for the large concentration of combustibles in the north turbine area (Fire Area 9A).
By letter dated January 23, 1980, the licensee indicated that an automatic sprinkler system designed to provide a ninimum density of 0.3 gpm/sq. ft, for fire area 9A would be provided. We informed the licensee that the pro-posed area sprinkler system was not acceptable since a single break in the 1
fire header could simultaneously impair operation of the wet pipe area sprinkler system and the cable tray water spray deluge system. We recommended that the licensee provide sufficient valves in the fire water system looped header to assure that a single break will not impair operation of the wet pipe area sprinkler system and any other automatic suppression systems for area 9A simultaneously.
By letter dated September 26, 1980, the licensee committed to. provide a separate feed from the yard loop with adequate valving to prevent the simul-taneous loss of both the cable tray water spray deluge system and the fusible link water sprinkler system due to a single pipe break.
The licensee's proposed modification meets Section E.3.(a) of Appendix A to BTP APCSB 9.5-1 and, therefore, is acceptable.
F0AM SUPPRESSION SYSTEM, SECTION 3.1.6 In the SER, it was our concern that the manual deluge system did not provide adequate fire protection for the lube oil reservoir and conditioner. We recomended that the deluge system for the lube oil reservoir and conditioner be modified to provide an automatic foam suppression system.
By letter dated January 16, 1980, the licensee proposed a foam system for this area. The licensee stated that the design density for the lube oil area foam system will be 0.16 gpm/sq. ft. We found the system was not adequate. We recommended that the foam system supply connection to the turbine building fire protection header be. isolated from the other. lube oil reservoir area protection systems by providing approved OS&Y valves.in the header. We also recommended that the system comply with the provisions of NFPA 16.
By letter dated September 26, 1980, the licensee proposed to modify the foam system connection to the yard loop so that it will be isolated from the other
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Based on the licensee's comitment to isolate the foam suppression system from other systems in the area and verification that the foam system meets NFPA 16, we conclude the foam suppression system is acceptable.
GAS SUPPRESSION SYSTEM TOTAL FLOODING HALON 1301 FOR 4160 VOLT SWITCHGEAR ROOM, SECTION 3.1.7(a)
In the SER, it was our concern that the fire protection for the 4160 volt switchgear room may not be adequate. We recomended that the licensee provide an automatic total flooding Halon 1301 gas suppression system and that the system be designed to permit a second application of the suppression agent.
By letter dated January 23, 1980, thelicenseeproposedtoprohideaHalon.1301 system for the 4160 V switchgear room..The system will be designed to provide a 6% concentration for a soak time of 10 minutes, and that the discharge time would be 10 seconds. We found that.the design criteria were not adequate.
We recommended that the licensee revise the design criteria of the proposed system to provide for a 7% concentration for a 20 minute soak time.
By letter dated September 26, 1980, thelicenseeprohidedtheresultsofa Halon system discharge test; showing higher concentration and soak time than the system was designed for. During the 15 minute time period the concentra-tion within the room ranged from a high of 10% initially to a low of 7.2%
after 15 minutes.
Based on the Ticensee's test results, we conclude the Halen 1301 system is capable of providing the recommended concentration for the required soak time. We conclude that the system meets Section E.4 of Appendix A to BTP APCSB 9.5-1 and therefore, is acceptable.
GAS SUPPRESSI0ft SYSTEM - TOTAL FLOODING HALON 1301 FOR 480 VOLT SWITCHGEAR ROOM, SECTION 3.1.7(b)
In the SER, it was our concern that the fire protection for the 480 volt switchgear room may not be adequate. We recommended that the licensee provide an automatic total flooding Halon 1301 gas suppression system.
By letter dated January 23, 1980, the licensee proposed to prohide a total flooding Halon 1301 system for this area. The system will be designed to provide a 6% concentration for a soak time of 10 minutes. We found that the design criteria are not adequate. We recomended that the licensee revise the design criteria of the proposed system to provide a 7% concentra-tion for a 20 minute soak time.
By letter dated September 26, 1980, the licensee. indicated that the Halon system for the 480 volt switchgear rocm will provide a 7% concentration for a 20 minute soak time. Additionally, the licensee comited to conduct a performance test of this system.
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' Basedonthelicensee'scommitmenttoproOideaHalonsystemforthe480 volt switchgear room capable of providing a 7% concentration for 20 minutes, we conclude that the system meets Section E(4) of Appendix A to BTP APCSB 9.5-1 and, therefore, is acceptable.
DELUGE SYSTEM FOR STATION SERVICE TRANSFORMERS, SECTION 3.1.15(8)
In the SER,.it was our concern that the fire protection provided for the station service transformer was not adequate. We recommended that the licensee either replace the oil with a silicone base oil or provide an automatic deluge system to protect the transformers.
By letter dated January 23, 1980, the licensee proposed to provide an automatic deluge system to protect the station service transformers. The system will comply with NFPA 15. Since the licensee did not specify the design criteria, we recommended that sufficient nozzles be provided to deliver a 0.3 gpm/sq. ft, water spray density over all surfaces of the transformers, including 0.15 on all non -absorbing ground surface area of exposure.
By letter dated September 26, 1980, thelicenseeproposedtoprohideadditional discharge nozzles to assure compliance with the recommendations of NFPA 15.
The specific design parameters are 0.25 gpm/sq. ft. over all surfaces of the transformers and 0.15 gpm/sq. ft. on expected non-absorbing ground surface.
These design parameters meet Section 4-4.3.4(a) of NFPA 15.
Basedonthelicensee'scommitmenttoprohideanautomaticdelugesystemwhich meets NFPA 15, we conclude that the protection for the transformers meets Section E.3(c) of Appendix A to BTP APCSB 9.5-1 and, therefore, is acceptable.
D0ORWAY OF 480 VOLT SWITCHGEAR ROOM, SECTION 3.1.15(9)
IntheSER,itwasourconcernthattheequipmentinsidethe480-Yoltswitch-gear room could be affected by a fire involving the transformer oil spreading through the doorway facing these transformers. We recormiended that the door-way of the 480-volt.swtichgear room facing the station service transformers be filled in to provide a fire barrier rating equivalent to the west wall of tne room.
By letter dated September 26, 1980, the licensee indicated that a three-hour rated fire door was installed in lieu of filling.in the doorway.
The three-hour fire rated door will not prevent oil from entering the 480-volt switchgear room in the event of spillage of the transformer oil in the adjacent transformers and, therefore, is not acceptable. The licensee should provide either a curb at the doorway to prevent oil from spreading into the 480-volt switchgear room via the doorway or remove the three-hour doors and fill in the doorway to provide a fire barrier rating equivalent to three-hours.
FIRE PROTECTION REVIEW STATUS 3
SAN ONOFRE 1 50-206 Item Descriotion Status
- 3.1.1 Fire Detection System C
3.1.2 Fire Water Supply C
3.1.5 Water Suppression System C
3.1.5(d)
Water Suppression System C
4 3.1.6 Foam Suppression System C
3.1.7(a)(b)
Gas Suppression System C
3.1.15(8)
Deluge System C
3.1.1 3
Fire Detection Systems R
(9(10)(11) 3.1.2(b Fire Water Supply R
3.1.5(a)
Water Suppression System R
3.1.5(c)
Water Suppression System R
3.1.15(9)
Doorway of 480-Volt Switchgear Room R
3.2.1 Alternate Shutdown Capability R
3.2.4 Cable Spreading Area R
3.2.5 Containment R
3.2.3 Turbine Building Structure UR C - Complete R - Requirement UR - Under Review
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FEB 4 1981 Docket No. 50-206 Mr. R. Dietch l
Vice President, Nuclear Engineering and Operations Southern California Edison Company 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770
Dear Mr. Dietch:
The Comission has issued the enclosed Supplement No. I to the Jul 197 af luation Report (FPSER) for the This supplement is in re erence o your submittals dated January
, and September 26, 1980, which provided details of installed Fire Protection Modifications and your responses to coments and recomendations dated April 16, and May 13, 1980 from our fire protection consultant, Brookhaven National Laboratory. This supple-ment provides our safety evaluation of the following items:
3.1.1 Control Room Fire Detection System 3.1.1 Smoke Detectors in Lube Oil Area 3.1.2 Fire Pump Test Features 3.1.2 Fire Water Supply - Isolation Valve 3.1.2 Fire Water Supply - Units 2 and 3 Connection 3.1.5 Water Suppression System - 480 Volt Switchgear Room 3.1.5 Water Suppression System - North Turbine Building Area 3.1.5 Water Suppression System - North Wall Structure 3.1.5 d)
Water Suppression System - Wet Pipe Area Sprinkler 3.1.6 Foam Suppression System 3.1.7(a)
Gas Suppression System - 4160 Volt Switchgear 3.1. 7(b)
Gas Suppression System - 480 Volt Switchgear 3.1.15 Reactor Coolant Pump 011 Collection System 3.1.15 Deluge System for Station Service Transformers 3.1.15 Doorway of 480 Volt Switchgear Room 3.2.2 Smoke Detection System Tests 3.2.3 Turbine Building Structure Some of the completion dates discussed in the Fire Protection Safety Evalua-tion Report for San Onofre Unit No. I are no longer valid as a result of the publication of a revised Section 10 CFR 50.48 and a new Appendix R to 10 CFR 50 on November 19, 1980.
The revised Table 3.1 included in Supple-ment No. I supersedes Table 3.1 of the July 19, 1979 FPSER. This revised
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FEB 4 1981 Mr. R. Dietch Table reflects the requirements that your items 3.1.15.5(011 Collection System for Reactor Coolant Pump) and 3.1.17 (Emergency Lighting) be revised to comply with the new Appendix R.
Table 3.1 also provides the status of our review of the fire protection program for San Onofre Unit No. I and supersedes Section 3.0 of your FPSER concerning accept-ability of design.
The enclosed Table 3.2 supersedes Table 3.2 of the July 19, 1979 FPSER.
This new-table reflects the acceptance of Items 3.2.2 and 3.2.3 and the issuance of a revised Section 10 CFR 50.48 and a new Appendix R to 10 CFR 50.
You will note that although item 3.1.11.e (Fire Stops in Cable Trays) was inadvertently indicated as complete in the FPSER, this item will be reviewed on a schedule consistent with 10 CFR 50.48 and is included in Table 3.2 of the enclosed Supplement.
Sincerely, A'{
in DennisT. 'Crutchfield, Cde:f Operating Reactors Branch #5 Division of Licensing
Enclosure:
Supplement No. I to the Fire Protection SER cc w/ enclosure:
See next page e
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4 6
8 9
Mr. R. Dietch E
4E 3,
cc w/ enclosure:
Charles R. Kocher. Assistant Otructor. Technical Assessment General Counsel Division Southern California Edison company Office of Radiation Prograss Post Office Box 800 (AW-459)
Rosemead. California 91770 U. S. Environmental Protection Agency David R. Pigott Crystal Mall #2 SSamuel B. Case Arlington, Virginia 20460 Chickering & Gregory Three Embarcadero Center U. S. Environmental Protection Twenty-Third Floor Agency San Francisco, California 94111
' Region IX Office ATTN: EIS COORDINATOR Jack E. Thames 215 Freement Street Harry B. Stoehr San Francisco, California 94111
- ' San Otego Gas & Electric Cosparty P. O. Box 1831 San Diego. California 92112 Resident Inspector c/o U. S. NRC P. O. Box AA Oceanside. California 92054 Mission Viejo Branch Library 24851 Chrisanta Drive Mission Viejo. California 92676 Mayor City of San Clemente San Clemente. California 92672 Chairan Soard of Supervisors County of San Otego San Diego, California 92101 California Department of Health ATTN: Chief. Environmental Radiation Control Unit Radiological Health Section 714 P Street. Room 498 Sacramento, California 95814 N