ML20153G250

Applications 39 & 25 for Amends to Licenses NPF-10 & NPF-15, Consisting of Proposed Changes 243 & 244,including Remote Shutdown Monitoring Instrumentation,Fire Detection Instrumentation & Spray &/Or Sprinkler Sys

ML20153G250
Person / Time
Site:	San Onofre
Issue date:	05/06/1988
From:	Baskin K SOUTHERN CALIFORNIA EDISON CO.
To:
Shared Package
ML13303A878	List: ML20153G250 ML20153G253
References
NUDOCS 8805110181
Download: ML20153G250 (29)

Text

- _ _ _ _ - _ _ _ _-

UNITED STATES OF AMERICA N_UCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA E0! SON )

COMPANY, EI AL. for a C' ass 103 License to ) DOCKET NO. 50-361 i Acquire, Possess, and Use a Utilization )

Facility as Part of Unit No. 2 of the San ) Amendment Application Onofre Nuclear Generating Station ) No. 39 SOUTHERN CALIFORNIA EDISON COMPANY, EI 6L pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 39. ,

This amendment application consists of the following proposed changes 243 and 244 to Facility Operating License No. NPF-10. Proposed Change 243 contains the following items: ,

l l i

1. Technical Specification Table 3.3-9, "Remote Shutdown Monitoring i Instrumentation" would be modified to allow for plant instrument improvements. I

2. Technical Specification 3.3.3.7, "Fire Detection Instrumentation" would be modified to differentiate between early warning fire  ;

i detectors and actuation fire detectors and change the technical specification nomenclature to that which is utilized in the Updated Fire Hazards Analysis (UFHA).

I

3. Technical Specification 3.7.8.2, "Spray and/or Sprinkler Systems" l would be modified to more clearly define required compensatory 4

actions for inoperable spray and/or sprinkler systems. This change ,

would also change nomenclature to that utilized in the UFHA. f 8805110181 880506

• DR ADOCK0500g1

4. Technical Specification 3.7.8.3, "Fire Hose Stations" would be modified to more clearly define required compensatory actions for inoperable fire hose stations. This change would also change nomenclature to that utilized on the UFHA.

5. Technical Specification 3.7.9, "Fire Rated Assemblies" would be modified to comply with current NRC guidelines for fire rated usemblies.

i

! 6. Technical Specification Bases 83/5.3.3.7, "Fire Detection Instrumentation" would be modified consistent with the changes described in (b) above.

i I

7. Technical Specifications 4.7.8.2, 4.7.8.3, 4.7.9.2 would be modified to change the current 18 month surveillance intervals to refueling outage intervals.

Proposed change 244 contains the following items:

1

1. License Condition 2.C(12) would be modified to reflect the revised fire protection program described in the Updated Fire Hazards Analysis and subsequent licensee submittals. NRC approval of SCE's program revisions is documented in the Updated Fire Hazards Analysis Evaluation For San Onofre 2 and 3, Revision 1 issued in May 1988,

2. License Condition 2.G would be modified to exempt fire protection program violations from 2 G reporting requirements.

m

3. Technical Specification 6.9.2, "Special Reports", would be modified to specify that violations of the fire protection program which would have adversely impacted the ability to achieve and maintain safe shutdown in the event of a. fire shall be reported within 30 a

days via the Licensee Event Report system.

Pursuant to 10 CFR 170.12, an amendment application fee of $150 is required for this amendment request. Accordingly, the Southern California Edison Company's check for $150.00 is enclosed.

1 I

I 9465F I

l 4

Subscribed on this b day of LA , 1988.

0 Respectfully submitted.

SOUTHERN CALIFORNIA EDISON COMPANY By: __, ,

Subscribed and sw(rn to before me this (s% day of n w 1988 .

0 . _-. _ . - . - -

$ ,8t24 h c.NLYSYN Notary Public 19 and for the County of LYs'EYt!s edUN Los Angeles, State of California wycan.op.v aiew My Commission Expires: M,/990 Charles R. Kocher James A. Beoletto Attorneys for Southern California Edison Company es

-x By: ,b, - ,, - '.N

SAN DIEGO GAS & ELECTRIC COMPANY

/

c6~11/

By: f - '

\

4 David R. Pigott Samuel B. Casey Orrick, Herrington & Sutcliffe Attorneys for San Diego Gas & Electric Company By:

/ 00~

o Subscribed and sworn t before me this '

m _ _ _ _ _ . ~ . _ .2/ day.of_ ../fS8==. :ar-STATE OF CALIFORNIAA ( SS  !

COUNTf OF W _ __ _ ________ ___ _ %

On __ .__ d/, _./ f 88_ _. before me, the undersigned, a Notary Public in and f or said State, personally appeared ___.j.1b _ _

_ __ _ _ __ _ __ _ __ a nd  ;;

_ _ _ . _ _ . _ _. _ ___ ___ _.._ _. _ _ __ _ ._ _ - _ ._ _ _ . _, personally known to me (or proved o me on the basis of satisf actory endencel to be the persons who executed the within instrument as b /

i . _._ _ _ _ _ President and __. _ _ ___ .. _ . _ ._ __ Secret ary, on be half o' _ _ _ _ _ . _ _ _ _ _ _

._ __ % 4- Ao V _ _ _ _ _

the corporation the in named and acknowledged to me that such corporation esecuted the w thin instrument pursuant to 9_ Its by la As or a resolution of its board of directors d

4 WITNESS my hand and oft.ciar sni m

1. ~

H senature >ddy /4 E M. 1 a g ; g h ia, ean PhMCIPAL CHICE se man rusan m am

% CBMWhMGS E89 A=4 al 6h I

l, SAN DIEGO GAS & ELECTRIC COMPANY S

By: -[ ~ '

e d#1?/M

\ ,

David R. Pigott Samuel B. Casey Orrick, Herrington & Sutcliffe Attorneys for San Diego .

Gas & Electric Company L

By: A N}' '

V Subscribed and sworn t before me this '

. 2/ day of . /958 .

l Nao au4 Not(ry PuM11c in and for the City LW l and County of San Diego, California n

) I  !

l I

)

i  ;

t i

l I f i

%en,U"'We w n 4*} f F

P

- ,,--._,r- --.-------.-,--ca-- m - r , , - m ,, --- ,-~, n--.,- -,c-- ,--- ---n - -w,-,- r -r- w-v---,yw- .w,-g- -,-,,---.--,g+ , -s--,

jl. 'y

,ii J'O h

P B

f l

'i

, k i

t s

I t

e

)

i h

l

- . wxM h;C * **' ;' i

--a - a ,..>-.n. . - . , . _. .-

• 2 o

STATE OF CAUFORNi COUNTY OF ___ _ _ _ . _ _ _ _ _ _ _ _ { SS.

On .

_d/.,_ /.8 88 -__ __. betere me. the undersigned. a Notary Pubbc 66 and f or sa4 State. personatly appeared _ .ja O_ __ -_-_ _ _ - and personalty known to re.e (or proved o me on the I

basis of satisfactory evidence) to be tne persons who esecuted tne within instrument as b.

p

_____ Pres. dent and __ _.._. _. _ _. _ _ .. Secretary. on behatt of _ . . .__ __

y

6 -  %- 2 tso 4 .. M .

the corporation the in named and acknow1 edged to me that such corporation esecuted the within instrument pursuant to e_ its by laws or a resolut'on of its board of directots

!5

~% WITNESS my hand and otteat seat ,

d> _

pr rial e gt)

Signature . -

M CHCl N i eam ruman en am

%_ ,.s

- - w .-. p L

THE CITY OF ANAHEIH d

't By: N34O '

N 4

, Alan R. Hatts Rourke & Hoodruff-

~ Attorneys for the City of Anaheim By:

Sublergedandsworntwbeforemethis c7/ ' day of // 4 12/ , /985' .

I-- @.= -

• CATHY g gg'2 GT[ "~"1 KARPOW

/ '

4 ,,,.... ...... .

! psigM Ae 08 t iCI 'N ORAhal COVNU l j

upmm ss odspiresMay19.1933 ',

. - + ~ ~ - - -

f gg,, y p ,)

Notary Public g an'd f6r the County of Orange. State of California

THE CITY OF RIVERSIDE s s By: $ aV Alan R. Hatts Rourke & Hoodruff Attorneys for the City of Riverside By: q d9 Subscribed and sworn to before me this 21st day of April 1988 .

. ~_ ~ - -~ r f ^ N AtsAn'gII.'Itc Avanti ( W a 4 w d d 84c/4 d e u ((

5 s '$f cji[jjfgj[ { Notary Pdblic in and for the County of

] 7 T intisisi c:nn I, Riverside , State of California 3

) . , T. My Comm Eso 5-6-91 )

,_ ,_ ---~-

g

?

4 i UNITED STATES OF AMERICA NUCLEAR R QQl.ATORY COMMISSION l

Application of SOUTHERN CALIFORNIA EDISON )  !

COMPANY, H E . for a Class 103 License to ) DOCKET NO. 50-362 l Acquire, Possess, and Use a Utilization )

Facility as Part of Unit No. 3 of-the San ) Amendment Application ,

Onofre Nuclear Generating Station ) No. 25  ;

SOUTHERN CALIFORNIA EDISON COMPANY, H E. pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 25. l This amendment application consists of the following proposed changes 243 and 244 to Facility Operating License No. NPF-10. Proposed Change 243 contains the following items:

1. Technical Specification Table 3.3-9, "Remote Shutdown Monitoring  ;

Instrumentation" would be modified to allow for plant instrument f improvements. [

2. Technical Specification 3.3.3.7, "Fire Detection Instrumentation" would be modified to differentiate between early warning fire detectors and actuttion fire detectors and change the technical I

specification nomenclature to that which is utilized in the Updated ,

Fire Hazards Analysis (UFHA).

t

3. Technical Specification 3.7.8.2, "Spray and/or Sprinkler Systems" I would be modified to more clearly define required compensatory actions for inoperable spray and/or sprinkler systems. This change would also change nomenclature to that utilized in the UFHA.

i h

t 4. Technical Specification 3.7.8.3, "Fire Hose Stations" would be modified to more clearly define required compensatory actions for inoperable fire hose stations. This change would also change nomenclature to that utilized on the UFHA.

5. Technical Specification 3.7.9, "Fire Rated Assemblies" would be modified to comply with current NRC guidelines for fire rated assemblies.

6. Technical Specification Bases 83/5.3.3.7, "Fire Detection ,

Instrumentation" would be modified consistent with the changes described in (b) above.

1

7. Technical Specifiestions 4.7.8.2, 4.7.8.3, 4.7.9.2 would be modified to change the current 18 month surveillance intervals to refueling outage intervals.

Proposed change 244 contains the following items:

1. License Condition 2.C(12) would be modified to reflect the revised fire protection program described in the Updated Fire Hazards Analys1< and subsequent licensee submittals. NRC approval of SCE's program revisions is documented in the Updated Fire Hazards Analysis Evaluation for San Onofre 2 and 3 Revision 1 issued in May 1988.

2. License Condition 2.G would be modifed to exempt fire proteciton program violations from 2.G reporting requirements.

3. Technical Specification 6.9.2, "Special Reports", would be modified to specify that violations of the fire protection program which would have adversely impacted the ability to achieve and maintain safe shutdown in the event of a fire shall be reported within 30 days via the Licensee Event Report system.

Pursuant to 10 CFR 170.12, an amendment application fee of $150 is required for this amendment request. Accordingly, the Southern California Edison Company's check for $150.00 is enclosed.

9466F

Subscribed on this b day of 31bstt , 1988.

r-Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY By: , ,

/

Subscribed and swort to before me this 6% day of DW /9FF .

o' - -

7 OFFCAL SEAL I

h. ,k[/ k[o l C SALLY SEBO i NotaryPublicYnandfortheCountyof l y tote $[sN"$

Los Angeles, State of California j -

'4cce rm. w aiw; My Commission Expires: OM R /990 U

Charles R. Kocher James A. Beoletto Attorneys for Southern California Edison Company l

m

\~,

I By:  % At:>

> T l

l

SAN DIEGO GAS & ELECTRIC COMPANY 7

By: <Wr# '

/ \

David R. Pigott Samuel B. Casey Orrick, Herrington & Sutcliffe Attorneys for San Diego Gas & Electric Company By:

\,

_ A e /p1 .j g/ d. -

Subscribed and sworn to before me this 21 day of _cletL L /9 8 G .

Y t

STATE OF CALIFORP A '

( SS.

COUNTY OF . _.y ' _7 F _ _ _ _...__ __._ \

On _ _,M[__. (([____ ___. before me, the undersigned a Notary Public in and for said State personauy appeared ___ a m - _ _ _ _ _ _ . . _ _ . _ and

- . . . . _ _ _._ _._. personalty known to me (or proved to ree on the basis of sat'sf actory evidence) to be the persons who esecuted the within instrument al _ _ _ _ ._ _ ___

,M _ President and _ _ . . _ Mcret4ry. on behalf of ,- _ . - _ _ _ _ . _

d e C hY _.

]

the corporation therein named. and ackno*1 edged to me that such corporation executed the *> thin instrument pursuant to its by-tans or a resolution of its board of d> rectors g

WITNESS my hand ana ottc=at seal -

{b; . _-

[

20 s.g nature ~ 1atW c. . ariWffMMWE trWR*' 'I ali es0fam pveuc4Atroma (

muc= onceei SMI 04GO NTY >

[.)

SAN DIEGO GAS & ELECTRIC COMPANY By: /w/ R

/ \

David R. Pigott Samuel B. Casey Orrick, Herrington & Sutcliffe Attorneys for San Diego Gas & Electric Company By: c/ m / i 1U I Subscribed and sworn to before me this 21 day of s/n y

M /988 .

s-gW L Notary fublic in and for the City and County of San Diego, California

\

l .

)

\  :

L w s - 2 ::a

n i

. . . -,e... .- _. _ _ _ m. _ t 1 STATE OF CALIFOR A COUNTY OF .__ _ . ': @ _____.... _) f SS On _. ._M b ___ j((_____ t>etore me. the unde s.gned, a Notary Puble in and for said State, personaky appeared _. . _.. _J. t _ S_ __ _ _ _ _ _ _ _ _ __ _ _ a nd

_ _ _ ___ _ _ _ _.--. _ ______ _-, personalty knom n to me (or proved to me on the basis of satisf actory evidence) to be the persons who enecuted the within instrument as .__._ _... _ _ _

_ _ _ . _ _ 4E-L _ Presdent and _ T___ . Oferetary, on behalf of . _ _ _ _ . _ _ _ _

O .i - # *' -

the corporate th rein named and acknowiedged to me that such corporation esecuted the n' thin instrument pursuant to 1 e ett by lans or a resolution of its board of d. rectors k

I" WITNESS my hand and off c.at seal ~~.

E Sqnature 144*f . C.,C_ OmDaL SEAL

$ ar ggggg[ (rggal 9 i all septarf PWuCOLFomesa PRSC MLOFFCIBe San DEGO COUNTY x

\

' I a

, ?_L 1. . ,

i < '

4 THE CITY OF ANAHEIM e

i l

l By: > *W- N v  :

1

., t

' Alan'R. Hatts Rourke & Hoodruff I a Attorneys for the City of Anaheim i d

e By: - -

M -

t t

I i

t

,cri i

_)/Jged anddaysworn tA before/7f of l/hil/ me tpis .

j.c.

w=em /

h g.wnerrsmeemr+*-v.we p3 (4 Fid A t. SF a-rve t. . s w-w( .

t c t gj~i4 CAT  ?

. m ee av. a s.. t i

f. gem ff t.

sewn!ty r ;- wor.o our1;t ex eiw.cc cousiv xAapow ,.

4 j

. Cj j m.,m,c. _Lh Cenencs i.mp_tes t.3/.19

.. , . DC9' " " ),

8/tv/ / If4A?M/ l

.m.- .

Notary Public ( Cand fof the County of Orange, State of California  !

I

} f I *

(

e r

i l

}

, s b

4 I

5

~ w ,,w s ,- r,,-- -ww m e n - --m m , w rrww w .. __ - ,- w,,

. ,m , n e ,-r w m enw-n _ w- mn, n n e n. n e, m w r ,. .,,,,-m r-ew,'

a THE CITY OF RIVERSIDE s

By: _s N Alan R. Hatts Rourke & Hoodruff Attorneys for the City of Riverside r

By:

i F

Subscribed and sworn to before me this 21st day of April. 1988 .

____ -.;- I. ARCunasAttIAMlHli 7'II4M b d tem puti c-coamr o {NotaryP6blicinandfortheCountyof

. *3 'y FR[j[Nt$[ht/" k Riverside , State of California l .- My ccmm tio. 54-91-- I g_ _ _ ~

t I

6 2

I

DESCRIPTION OF PROPOSED CHANGE NPF-10/15-243 AND SAFETY ANALYSIS This is a request to revise Technical Specification 3/4.3.3.7, "Fire Detection Instrumentation"; 3/4.7.9, "Fire Rated Assemblies"; 3/4.7.8.3, "Fire Hose Stations"; S/4.7.8.2, "Spray and/or Sprinkler Systems"; and Table 3.3-9, l "Remote Shutdown Monitoring Instrumentation", and Table 4.3-6, "Remote Shutdown Monitoring Instrumentation Surveillanca Requirements."

Existing Soecifications j Unit 2: See Attachment "A" Unit 3: See Attachment "B" Procosed Soecifications Unit 2: See Attachment "C" Unit 3: See Attachment "0" Descriotion This proposed change would modify the Technical Specifications in the following manner:

a) T. S. Table 3.3-9, "Remote Shutdown Monitoring Instrumentation" -

This table provides a listing of the required instruments for the remote shutdown panel (RSP) along with the instrument channel range. This proposed change would revise the stated RCS cold leg temperature range from 0-6000F to 0-7000F. The RCS hot leg temperature range would similarly be changed from 190-6250F to

0-7000F. This change also clarifies the need to have RCS cold and l hot leg temperature indication at RSP L411 only. This change would al

o delete Reactor Coolant Boron Concentration Instrument display ,

and [eplace i+ with source range neutron flux indication 5

(10-i-10 CPS) [These changes are to be effective upon l completion of DCPs 6604, 6160.2J and 6554.]

T. S. Table 4.3-6, "Remote Shutdown Monitoring Instrumentation Surveillance Requirements" - ,

This table provides a listing of RSP instruments and the associated surveillance requirements. The proposed change would replace reactor coolant boron concentration with source range neutron flux to be consistert with the changes to table 3.3-9. [These changes are to be effictive upon completion of DCPs 6604, 6160.2J and 6554.]

i b) Technical Specification 3.3.3.7. "Fire Detection Instrumentation" 1 1 and the associated Table 3.3-11 specify the number of heat, smoke, i

and flame detectors that must be operable for each designated fire ,

zone in the plant and the actions that must be taken when detection equipment is inoperable. Currently, this technical specification .

requires 100% of all early warning and actuation fire detectors in j each fire zone to be operable. With less than the required number i of detectors operable in any zone, an hourly fire watch patrol must be established within I hour. For instruments inside containment, the specification requires an inspection within the containment at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or that the containment air temperature be  !

monitored at least once per hour. The proposed change would allow up to 50% of the early warning detectors in a specific fire

area / zone to be inoperable for up to 14 days after which an hourly fire watch patrol must be established within one hour. If m;re than 50% of the early warning detectors in a specific area / zone are-i inoperable or with ar.y two adjacent early warning detectors inoperable, an hourly fire watch must be established within one  :

hour. For actuation detectors, Sny less than the number specified [

in Table 3.3-11 operable, an hourly fire watch must be established .

within one hour. The actions required for detectors inside l containment would remain unchanged. This proposed change would also  ;

allow the fite patrol / watch requirement to be suspended for areas that pose temporary radiation and/or life-threatening safety hazards. However, if the fire watch must be suspended for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, a Special Report must be prepared and submitted to the Commission within the next 7 days that outlines the actions to be i i taken to restore the fire watch.

This proposed change would also replace the current numerical I identification of each plant fire area / zone with the designations

] used in the Updated Fire Hazards Analyses. (Attachment E of this I i

package provides a cross reference that indicates which "old" Fire Zone number corresponds to the "new" Fire Area / Zone designators.)

) Also, this change would replace the use of "fire detection zone" .

I with "fire detection area / zone." This change also modified  !

Table 3.3-11 to reflect only fire detection systems which protect t safe shutdown and/or safety related (not required for safe shutdown) i i equipment based on the Updated Fire Hazards analysis and the  !

10 CFR 50, Appendix R reassessment performed in light of Generic Letter 86-10 guidance.

i This process resulted in the following changes: 7 l

j 1. The suppression system protecting charcoal filters is actuated l th,*ough mariual operator action. Therefore, the detector which

! provided automatic actuation capability is no longer necessary

since the early warning detector is required to be operable.

! Thus, charcoal filters now reflect one of two detection systems l to be operable, instead of both (A note is added to the end of l

j Table 3.3-11 which requires the thermistor strip detection system to be operable for charcoal filters)- >

i i f

l 1

2. Areas which appeared on the current Table 3.3-11 with "none" entered for detectors have been deleted; -

3. Areas which do not contain safe shutdown or safety related systems have been deleted.

This proposed specification also adds two fire area / zones (2-AR-50-111A and 2-AR-50-1118) to this table. The list of detectors has been revised to reflect the total number of detectors installed in a given fire area / zone required to protect safe shutdown and/or safety-related equipment. At the NRC's request, SCE is installing additional early warning detectors in fire zone 2-AC-30-20A; the revised table reflects these new detectors upon completion of DCP 2/3-6554.36 TJ. This proposed change also removes the distinction between heat, smoke and flame type detector classes for both early warning and actuation detectors and continues to distinguish only between early warning detectors and actuation detectors.

c) Technical Specification 3.7.8.2, "Spray and/or Sprinkler Systems" -

This specification and the associated Table 3.7-5, "Safety Related Spray and/or Sprinkler Systems," designate what actions must be taken when any of the systems listed in Table 3.7-5 are inoperable.

Currently, when any spray and/or sprinkler system outside containment that protects redundant equipment is inoperable, a continuous fire watch with backup fire suppression equipment must be established within one hour. For systems that protect other areas outside containment, an hourly fire watch patrol must be established within one hour. This proposed change would modify this action statement by the addition of two footnotes. The first footnote suspends the fire watch requirement when affected areas pose temporary radiation and/or life threatening safety hazards; however, if the fire watch cannot be restored, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, a Special Report must be submitted within the next 7 days. The second footnote provides clarification to delineate what constitutes the establishment of backup fire suppression equipment. The second -

~

footnote states:

"Fire hose will be run within one-hour of entering the ACTION statement if an operable water supply is not available within

! 250 feet of the area protected by the inoperable spray and/or sprinkler system or 2-150 ft. hose packs (1-3/4") on the fire engine are not operable. Fire hose will be supplied by the fire brigade responding to a fire if an operable water supply is available within 250 feet of the area containing the ,

inoperable spray and/or sprinkler system."

This proposed change would also modify Table 3.7-5, "Safety Related Spray and/or Sprinkler Systems," in the following way:

l ,

l

- - - _ , - - - - - , , - . , . . - , . . ,, , . , - _ _ - _ r , ., - , , - _ , . - ~ . - _ _ , _

,n,,- -. ..n , , , _ -._n -- - _ , .

1) The title of this table would be changed to "Required Sprinkler and Spray Systems" to more accurately indicate that these are the spray and/or sprinkler systems that are required to be operable.

2) The current column entitled "Hazard" would be changed to "Fire Area / Zone." Correspondingly, the column of information would change from a general plant area to a specific Updated Fire Hazards Analysis fire area / zone designator.

3) The current column entitled "Location" would be changed to "Location of Protection." Correspondingly, the column of information would change to a more specific fire area description with plant elevation reference similar to the UFHA.

4) The current column entitled "No. of Systems" would be changed to "System Identifier." The new system identifiers are the numbers utilized by San Onofrc's computerized plant equipment data base. Additionally, where the old table indicated more than one system, the new table is expanded to detail each individual system.

5) Table 3.7-5 was modified to reflect only spray and/or sprinkler systems which protect safe shutdown and/or safety related (not required for safe shutdown) equipment based on the Updated Fire Hazards Analysis and the Appendix R reassessment performed in light of Generic Letter 86-10 guidance. This resulted in removing spray and/or sprinkler systems in the following areas from Table 3.7-5:

o The railroad tunnel in the fuel handling building o The truck ramp in the radwaste building d) Technical Specification 3.7.8.3, "Fire Hose Stations," and the associated Table 3.7-6, "Fire Hose Stations," describe which fire hose stations are required to be operable and the actions to be taken when one or more hose station (s) are inoperable. Currently, with one or more hose stations inoperable and the hose station (s) are the primary means of fire suppression for the affected area, an alternate fire hose of equivalent nozzle flow capacity mu:,t be routed to the affected area within one hour. If the inoperable hose station (s) to the affected area are not the primary means of fire suppression, an alternate hose must be provided within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. In all cases, if routing of a hose would present a danger to technicians or plant equipment or the hose itself, the additional ilose is to be stored in an area easily accessible from the affected area. The affected hose, the backup hose and all associated valves are to be labeled appropriately. The proposed change would not require fire hose to be routed for inoperable hose stations that are within 250 feet of an operable water source by stating:

l l

"Fire hose will be run within I hour of entering the ACTION statement when an operable water supply is not available within ,

250 feet of the inoperable hose station (s) or 2-150 ft. hose packs (1-3/4") on the fire engine are not operable. Fire hose i will be supplied by the fire brigade responding to a fire if an operable water supply is available within 250 feet of the inoperable hose station.

I The current specification does not differentiate between the actions to be taken for inoperable hose stations inside or outside containment. The proposed specification would require hose stations t inside containment, when the equipment hatch closed, to be restored -

to operable within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or, in lieu of any other report required by Specification 6.9.1, prepare and submit to the commission a special report pursuant to Specification 6.9.2 within 7 days. This report must detail the action taken, the cause of the inoperability and the plans and schedule for repairing the inoperable hose station. The proposed change would delete the requirement to label the valves associated with the backup hose / water supply. Signs will still be required to be posted on the inoperable hose station.

This proposed change would also modify Table 3.7-6, "Fire Hose ,

Stations," by adding a new column "Fire Area / Zone." This new column l would allow more accurate identification of each specific hose station. This proposed change also adds 31 hose stations to this technical specification table that are installed in the plant but not currently listed in Table 3.7-6. The added hose stations are:

Station No. Location

• 24 Turbine Bldg.

28 A/C Room - Safety Equipment Bldg.

, 29 A/C Room - Safety Equipment Bldg.

i 31 Piping Room - Safety Equipment Bldg.

Corridor - Auxiliary Radwaste l 32 33 Corridor - Auxiliary Radwaste 34 Corridor - Auxiliary Radvaste 36 Corridor - Auxiliary Radwaste ,

37 Corridor - Auxiliary Radwaste 38 Corridor - Auxiliary Radwaste 40 Corridor - Auxiliary Radwaste 41 Corridor - Auxiliary Radwaste Roof - Auxiliary Control 42 43 Roof - Auxiliary Control 44 Corridor - Auxiliary Radwaste i

t I

Station No. Location 45 Corridor - Auxiliary Radwaste  ;

46 Corridor - Auxiliary Radwaste 47 Corridor - Auxiliary Radwaste 52 Cable Spreading Rm Corridor - Auxiliary Control ,

53 Lobby - Auxiliary Radwaste 54 Lobby - Auxiliary Control i 55 Corridor - Auxiliary Control '

58 Corridor - Auxiliary Control 59 Corridor - Auxiliary Control 63 Office Area - Auxiliary Control  ;

95 Intake Structure 101 Hall-Mezzanine - Auxiliary Control ,

102 Corridor - Auxiliary Radwaste -

103 Corridor - Auxiliary Radwaste ,

106 Corridor - Auxiliary Radwaste 107 Corridor - Auxiliary Radwaste Currently, some Unit 2 hose stations are listed in the Unit 3 ,

specification and vice versa. This tabl? would be further modified by listing only Unit 2 hose stations in the Unit 2 specification and I listing only Unit 3 hose stations in the Unit 3 specifications, e) Technical Specification 3.7.9 describes which fire rated assemblies and fire rated assembly penetrations are required to be operable, when they are required to be operable and the actions to be taken

, when one or more fire rated assembly / assembly-penetration are t inoperable. Currently, all fire rated assemblies in walls, i floors / ceilings, cable tray enclosures and other fire barriers separating safety related fire areas or separating portions of -

i redundant systems important to safe shutdown within a fire area and i all sealing devices in fire rated assembly penetrations (e.g., fire 3

doors, fire windows, fire dampers, cable, ventilation ducts, and riping penetration seals) are required to be operable at all times.

When one or more fire rated assemblies and/or sealing devices are t inoperable, a continuous fire watch must be posted on at least one

]

side of the affected assembly within one hour or the operability of '

the fire detectors on at least one side of the inoperable assembly 1 must be verified and an hourly fire watch patrol established. The ,

i proposed change would require the operability of only those fire rated assemblies and all associated fire barrier sealing devices that separate redundant equipinent or cable which could affect the ability to achieve and maintain safe shutdown in the event of a fire ,

or that define areas of the plant which have specific BTP 9.5-1 Appendix A, Section F requirements. These fire rated assemblies and i assembly penetrations are required to be operable only when the '

equipment protected by them is required to be operable. The proposed action required when one or more of the required fire rated

, assemblies becomes idoperable includes establishing a roving fire ,

watch patrol within one hour for areas with detection and/or

_ . . - _ _ . _ - _ _ _ . - _ . _ _ _ _ _ _ _ ~ _ _ _ _ _ _ _ _ _ _ _ - . - - - _ .

i suppression equipment operable on one side of the affected barrier.

For area (s) with no detection or suppression equipment operable on one side, a continuous fire watch will be posted. This proposed change would also allow the fire patrol / watch requirement to be suspended for areas that pose temporary radiation and/or life-threatening safety hazards. However, if the fire watch must be suspended for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, a Special Report must be prepared and submitted to the Commission within 7 days that outlines the actions to be taken to restore the fire watch, f) Technical Specification Bases B 3/4.3.3.7, "Fire Detection Instrumentation" would be modified to specify that up to 50% of the early warning fire detectors can be inoperable for up to 14 days before requiring any actions to be taken. This change is consistent with the changes described in (b) above. Additionally, the bases would be modified so that the bases for inspection of fire detectors following a seismic event (.05g) would correspond to the threshold level in the associated action statement.

g) This proposed change would also modify Technical Specifications 4.7.8.?, "Spray and/or Sprinkler Systems;" 4.7.8.3, "Fire Hose Stations;" and 4.7.9.2, "Fire Rated Assemblies" by changing the required 18 month surveillance interval to refueling intervals only for those plant areas that are inaccessible during non-refueling plant operation. This change is consistent with recent changes approved by the NRC for the Calvert Cliffs Nuclear Generating Station.

Safety Analysis The proposed changes discussed above shall be deemed to involve a significant hazards consideration if there is a positive finding in any one of the following areas (discussed per Technical Specification Change Description section from above):

1. Hill operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No Section a) -- The change in the range of RCS cold and hot leg temperature ranges provides for consistency between hot and cold leg indicators and corresponds to the wide range hot and cold leg temperature scales in the main control rc,om. Additionally, because RCS hot and cold leg te:eperature indicators may not remain operable at LO42 during some mergencies requiring nain control room evacuation, it is desirable to have RCS hot and cold leg temperature indication cperable at L411. All indicators located at L411 are both physically and electrically independent of the control room and, therefor.t. will remain operable should control roort evacuation be necessa"y. The boron concentration indicator is a non-safety related

display that, during emergency conditions, is not loaded onto the emergency buses. Therefore, boron concentration indication at the RSP is not currently available during emergency operations performed at LO42 with a concurrent loss of offsite power. Source range neutron flux is safety related and provides valuable information to the control operator during emergency operation.

Thus, this change improves operator response during use of the Remote Shutdown Panel and ensures the availability of required

' instrumentation. Because this change improves operator response capability to emergencies by enhancing remote shutdown indication, the probability or consequences of a previously evaluated accident are not increased.

Section b) -- The existence of fire protection features such as fire area boundaries, early warning and actuation fire detectors, automatic suppression systems, manual hose stations and portable extinguishers, coupled with the response of the San Onofre full-time l five-man fire department, provide a defense-in-depth capability to mitigate the effects of a fire in any plant area. The proposed change would increase the time allowed to restore inoperable early warning fire detectors (up to 50% of total early warning detectors) to operable status prior to establishing an hourly fire watch.

l Although this change would allow a greater number of early warning l fire detectors to be inoperable and lengthen the corresponding time period for implementing compensatory measures, it would not result in a significant increase in the probability or consequences of an accident previously evaluated due to the remaining features which comprise the defense-in-depth fire protection capability.

Additionally, detailed fire hazards analyses have demonstrated the ability to achieve and maintain safe shutdown for a fire in any plant area. Because the actions required to be taken when actuation detectors become inoperable will remain unchanged, the level of plant protection would remain unchanged. Sufficient early warning detectors would still be operable for positive control room indication of fire area / zone fire status. (The NRC has already approved this treatment of early warning fire detectors at four nuclear plant sites that were licensed after San Onofre Units 2 and 3.) Removing differentiation between heat, flame and smoke detectors (both early warning and actuation detectors) does not decrease the number of available detectors to respond to plant conditions. It does simplify the treatment and requirements for all detectors.

Th2 portion of this change that deletes actuation fire detectors from the system that protects charcoal filters is justified in that this protection system is currently manually operated. Therefore, the detector that provided automatic actuation capability is not required. Additionally, the charcoal filters have a thermistor strip detection system that is required to be operable.

The portion of this change that allows recognition of possible life threatening hazards is intended to allow SCE to conform to State and Federal guidelines regarding personnel safety and not violate the technical specifications concurrently. Changing the numerical  !

identification of each fire area / zone to those used in the UFHA ensures consistency, more precise referencing and is editorial in nature.

Section c) -- The intent of this proposed change is to recognize the  ;

rapidity at which hose that is less than 250 feet in length can be supplied and therefore the lack of a need to, in all cases, lay hose to account for inoperable spray and/or sprinkler systems. San Onofre has a dedicated, full-time, five-man (minimum) fire department providing coverage on a 24-hour basis. The fire department consists .

entirely of State Certified Fire Fighters / Emergency Medical Technicians. The fire department is trained in fighting the types of fires encountered in nuclear power plants. Frequent drills are held to maintain effectiveness and provide regular training in the use of Fire Pre-Plan 1. These drills allow the fire department to retain knowledge of the specific locations of available fire suppression equipment, including hydrants and hose stations, within each fire -

area. In addition to verifying that fire department physical agility requirements are achieved, training includes supplementing and pre-staging of equipment and hoses to be utilized for firefighting efforts. The following squipment is immediately available to support firefighting efforts and supplement training. A fully equipped fire engine including a minimum of 1000 ft. of 2-1/2" diameter or larger hose, 200 feet of 1-1/2" diameter or larger hose and two hose packs each consisting of 150 feet of 1-3/4" hose, all of which are always taken with the fire attack team.

The existing technical specificatier. requirement to provide '

compensatory hose was developed to support "fire brigade" efforts.

Hith the addition of the full-time fire department at San Onofre in 1982, manual fire suppression responsibilities were placed entirely on the fire department. When responding to fires, the fire department normally utilizes equipment and hoses transported to the fire by the fire attack team. Since the initial response capability of the fire department includes the above described equipment, no significant addition to the time required to dispense suppression agents is to be expected. Therefore, the time for agent application closely resembles that required if compensatory measures were pre-staged. This practice provides acceptable alternate measures for  !

manual suppression in lieu of the need to pre-stage compensatory hose for inoperable spray and/or sprinkler systems.

This proposed change will still ensure that adequate fire hose coverage is available to all areas regardless of which spray and/or sprinkler may be inoperable. Thus, because adequate coverage is maintained, the probability or consequences of an accident previously evaluated remain unchanged.

t r

L i

,-,m,-,-,,---,, -...n,e-,w---,n,-,n--,-,,,n ,,-----,,nn,---~--n, .

The changes to Table 3.7-5 have been proposed to provide additional information and to more clearly identify which spray and/or sprinkler

, systems are required to be operable. This modified Table 3.7-5 corresponds to the conventions utilized in the Updated Fire Hazards Analysis as well as with San Onofre's computerized plant equipment data base. Because this revised table requires the same spray and/or sprinkler systems in areas / zones containing safe shutdown or safety related (not required for safe shutdown) equipment to be operable as the unrevised table, the probability or consequences of an accident previously evaluated remain unchanged. Two spray and/or sprinkler systems were removed from Table 3.7-5:

o The railroad tunnel in the fuel handling building 1

o The truck ramp ir the radwaste building However, because there are no systems that protect safe shutdown or i scfety related systems in these areas, the consequences of an accident previously evaluated remain unchanged.

The portion of this change that allows recognition of possible life threatening hazards is intended to allow SCE to conform to State and

! Federal guidelines regarding personnel safety and not violate the technical specifications concurrently. Because this change does not modify the plant in any way, this change does not inc lase the probability of any accident previously evaluated.

! Section d) -- The intent of this proposed change it to recognize the rapidity at which hose that is less than 250 feet in length can be

laid and therefore the lack of a need to, in all cases, lay hose to

account for an inoperable hose station. As discussed in the response

for Section 'c' above, the practice of utilizing the initial response l capability of the fire department and associated equipment provides acceptable alternate measures for manual suppression in lieu of the l need to pre-stage compensatory hose for inoperable hose stations.

l This proposed change will still ensure that adequate fire hose

coverage is available to plant areas regardless of which fire hose station may be inoperable, thus, the probability or consequences of an accident previously evaluated remain unchanged.

The portion of this change that addresses hose stations inside i containment when the equipment hatch is closed is made to provide consistency between spray and/or sprinkler systems inside containment and hose stations inside containment. Currently, the technical

! specifications require a special report when spray and/or sprinkler

, systems (major fire suppression system) inside containment become

! inoperable. Because this practice is acceptable for the plant major

! fire suppression systems which protect major fire hazards inside

! containment, more restrictive actions for suppression system which

! provide coverage for other areas inside containment with reduced fire l hazard potential (hose stations) is not necessary, n

o The change to Table 3.7-6 adds information (fire area / zone i designators) to the Technical Specifications and adds additional fire i hose stations to supplement those which have been deemed necessary to i fight a fire in areas containing safe shutdown or safety related systems. Therefore, because this change only adds information, this change does not change the probability or consequences of an accident ,

previously evaluated.  !

i The portion of this change that allows recognition of possible life l threatening hazards is intended to allow SCE to conform to State and Federal guidelines regarding personnel safety and not violate the technical specifications concurrently.

Section e) -- This change clarifies the provisions made to comply with the requirement to protect the ability of the plant to achieve and maintain safe shutdown and BTP 9.5-1, Appendix A Section F. l This change also allows credit to be taken for existing fire ,

suppression systems (spray and/or sprinklers) as providing protection  !

equivalent to that provided by the fire detection systems. Because this change affects only which fire area / zones must have operable fire barriers and does not adversely affect the operability systems / components utilized to achieve and maintain hot standby and cold shutdown, this change does not increase the probability or consequence of any accident previously evaluated.

The portion of this change that allows recognition of possible life threatening hazards is intended to allow SCE to conform to State and Federal guidelines regarding personnel safety and not violate the technical specifications concurrently.

Section f) -- This change is editorial only and, therefore, does not increase the probability or consequence of any accident previously evaluated.

Section g) -- When the original Technical Specifications were drafted, those surveillances that were deemed by the NRC to be required once per plant refueling cycle were designated as "18 month" surveillances. This corresponded with a 12 month plant refueling cycle and thus, the 18 month surveillances were easily accommodated.

However, San Onofre Units 2 and 3 (as well as other nuclear plants) have extended each fuel cycle to 24 months. As a result, 18 month surveillances can no longer be completed for all plant areas without necessitating a mid-cycle outage. This change from "18 months" to "refueling outage" is required to prevent plint shutdowns that would otherwise be required to provide for Technical Specification surveillance in areas which are normally inaccessible during power operation (i.e., inside containment and other high radiation areas).

Because this type of change to certain fire protection Technical Specification surveillance intervals has already been approved by the NRC at another nuclear plant (Calvert Cliffs), the NRC has already

I  !

determined that this change does not increase the probability or consequences of any accident previously evaluated; nor does it create the possibility of a new or different type of accident from any previously evaluated; nor does it involve a significant reduction in a margin of safety.

2. Hill operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident from any previously evaluated?

Response: No Section a -- This change improves operator response during emergency conditions as discussed in response to Question 1 above. Therefore, because the manner in which the plant is operated or functions remains unchanged, operation of the facility in accordance with this proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

Section b -- As discussed above, this change modifies only the treatment of early warning fire detectors. The accidents previously evaluated considered the loss of all unprotected safe shutdown components within a fire area except where justified through deviation requests which were approved by the NRC. The actions required to be taken for inoperable actuation fire detectors will remain the same. Therefore, plant response to a fire will remain the same. Thus, operation of the facility in accordance with this proposed change will not create the possibility of a new or different kind of accident from any previously evaluated.

The portion of this change that allows recognition of possible life threatening hazards is intended to allow SCE to conform to State and Federal guidelines regarding personnel safety and not violate the technical specifications concurrently. This change does not create the possibility of a new or different kind of accident from any previously evaluated.

Section c -- As discussed in response to Question 1 above, this change affects only those plant fir; area / zones that have equivalent alternate protection as that provided by the spray and/or sprinkler systems. Because this change only affects the decision of whether or not to lay hose that is less than 250 feet from an alternate water source, operation of the facility in accordance with this change does not create the possibility of a new or different kind of accident from any previously evaluated.

The portion of this change that allows recognition of possible life threatening hazards is intended to allow SCE to conform to State and Federal guidelines regarding personnel safety and not violate the

technical specifications concurrently. This change does not create the possibility of a new or different kind of accident from any previously evaluated.

Section d -- Because this change only affects the decision of whether ,

or not to lay hose that is less than 250 feet from an alternate water source, operation of the facility in accordance with this proposed  ;

change will not create the possibility of a new or different kind of accident from any previously evaluated.  !

The portion of this change that allows recognition of possible life threatening hazards is intended to allow SCE to conform to State and Federal guidelines regarding personnel safety and not violate the technical specifications concurrently. Because this change does not modify the plant in any way, this change does not create the possibility of a new or different kind of accident from any previously evaluated.

Section e -- This change clarifies which fire barriers are required '

to be operable and where they are required. Since this change does not affect the ability to achieve and maintain safe shutdown, operation of the facility in accordance with this change does not create the possibility of a new or different kind of accident from any previously evaluated.

The portion of this change that allows recognition of possible life i threatening hazards is intended to allow SCE to conform to State and Federal guidelines regarding personnel safety and not violate the technical specifications concurrently. This change does not create the possibility of a new or different kind of accident from any previously evaluated.

Section f -- This change is editorial only.

Section g -- See response to Question 1 Section (g) above.

3. Hill operation of the facility in accordance with the proposed change involve a significant reduction in a margin of safety?

Response: No Section a -- As discussed above in response to Question 1, this change improves operator response. Therefore, operation of the facility in accordance with this change does not affect any margin of safety.

Section b -- Because this change does not modify actuation fire detectors and does not affect other fire protection features which comprise the defense-in-depth capability, operation of the facility in accordance with this change does not involve a significant reduction in a margin of safety.

Section c -- The intent of this proposed change is to recognize the rapidity at which hose that is less than 250 feet in length can be laid and therefore the lack of a need to, in all cases, lay hose to account for an inoperable spray and/or sprinkler systems. This proposed change will still ensure that adequate fire hose coverage is available to all areas regardless as to which spray and/or sprinkler systems may be inoperable. Therefore, operation of the facility in accordance with this proposed change does not involve a significant reduction in a margin of safety.

Section d -- The intent of this proposed change is to recognize the rapidity at which hose that is less than 250 feet in length can be laid and therefore the lack of a need to, in all cases, lay hose to account for an inoperable hose station. This proposed change will still ensure that adequate fire hose coverage is available to all areas regardless as to which fire hose station may be inoperable.

Therefore, operation of the facility in accordance with this proposed change does not involve a significant reduction in a margin of safety.

Section e -- As discussed in response to Questions 1 and 2 above, operation of the facility in accordance with this proposed change does not involve a significant reduction in a margin of safety.

Section f -- This change is editorial only.

Section g -- See response to Question 1, section (g) above.

Safety and Significant Hazards Determination Based on the above Safety Analysis it is concluded that: 1) the proposed change does not constitute a significant hazards consideration as defined by 10 CFR 50.92; 2) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed change; and 3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.

CEH:0618H

ATTACHMENT "A" 1