ML20199B108

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Forwards 10CFR50,App R,Section Iii.G Compliance Evaluations for Listed Fire Areas/Zones,Per New Guidance Provided During 860519-23 Fire Protection Audit
ML20199B108
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 06/06/1986
From: Morgan H
SOUTHERN CALIFORNIA EDISON CO.
To: Martin J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
TAC-64883, NUDOCS 8606170024
Download: ML20199B108 (36)
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Southern Califomia Edison Company SAN ONOFRE NUCLEAR GENERATING STATION P. O. BOX 128 SAN CLEMENTE CAllFORNIA 92672 H.E. MORGAN TELEPHONE S707:0N SAA; EAGER (7141368 6241 June 6, 1986 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 No. 50-206 10 CFR 50 Appendix R III.G Compliance Evaluations San Onofre Nuclear Generating Station, Unit 1 During the San Onofre Unit 1 Fire Protection Audit, May 19 thmugh 23, 1986, the inspection team provided new guidance regarding the acceptaa? '

means of demonstrating compliance with Section III.G of 10 CFR 50, Appendix R. The application of this new guidance resulted in the need to

) reevaluate the III.G.1 compliance evaluations previously submitted to NRR and resubmit evaluations or requests for exemption where appropriate.

Therefore, as requested by the NRC Inspection Team, provided as an enclosure to this letter are 10 CFR 50 Appendix R III.G Compliance Evaluations for the following Fire A'rea/ Zones:

1-TB-8-9A 1-TB-35-9B 1-PB-20-11 &l 2 1 - PB-20-13 l 1-PB-20-25 l 1 - PB-56-33

( 1 - AB-11 -34 If you have any questions, or if we can provide additional information, please let me know.

Sincerely, 860617o024 e60606 6 PDR ADOCK O$00 _

Enclosure cc: F. R. Huey, USNRC Senior Resident Inspector, Units 1, 2 and 3 i

G. E. Lear, Director, PWR Project Directorate No.1 Ii J JE-oI

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j 10 CFR 50, APPENDIX R SECTION III.G

- COMPLIANCE EVALUATIONS i

SAN ONOFRE NUCLEAR GENERATING STATION j UNIT 1 I

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s, FIRE ZONE EVALUATION 1-TB-8-9A TITLE: Turbine Building Ground Floor FIGURE: 3-1 INTRODUCTION This evaluation is provided to demonstrate compliance with 10 CFR 50, Appendix R, Section III.G.3 by demonsrating that for a fire in fire zone 1-TB-8-9A, Turbine Building Ground Floor, the dedicated safe shutdown-

- equipment is independent of the zone.

i AREA DESCRIPTION Physical Characteristics The turbine building ground floor contains the condenser and main feedwater pump areas, the turbine lube oil reservoir area, and the auxiliary feedwater pumps . The north wall of the zone, which separates the zone from 4160V switchgear room (1-PB-14-8) is 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated. The walls of the lube oil storage shed (1-TB-14-10) are also 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated. The wall adjoining the east and west penetration zones '(1-YD-20-4A,1-YD-20-48), and the east and south walls of the 480V switchgear room (1-FH-14-7) are 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> rated. The remainder of the zone walls are constructed of concrete block or reinforced concrete.

Three hour rated doors allow access to the 4160V. switchgear room, the 480V switchgear room, and the lube oil storage shed. A 1-1/2 hour rated door opens to the adjacent condensate storage tank area (1-YD-14-4F).

This zone has many unsealed openings. The major openings are listed below:

1. The east wall adjoining zone 1-TB-14-90 has a louvered area on the north end which extends 6'-0" down from the ceiling and 31'-6" to the south.

The south end of this wall also has a 3'-3" wide louvered area which l extends from the ceiling to within 7'-0" of the floor. There is a 6" gap

flashed with steel which runs the length of the wall just below the ceiling.

2.. In the south end of the zone, the wall which separates the zone from the

, exterior has a 10'-8" opening which extends from the floor to the ceil ing. This opening is covered by sheet metal but is unsealed.

3. The west wall of the zone adjoining zone 1-YD-14-4F has an area of louvers 19" below the ceiling extending 6'-6" and to the south 33'-6".
4. The south wall of the zone adjoining 1-)D-14-4F has numerous pipe and conduit penetrations distributed across the wall. The largest of these

, is 14" in diameter. A nonrated door also provides communication to l - YD-14-4 F.

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FIRE ZONE EVALUATION 1-TB-8-9A

5. The west wall of the zone adjoiling zone 1-YD-14-4D has a 3'-0" by 7'-0" door located approximately 51' 0" from the south end of the wall, a 10'-0" by 12'-0" door loca ted approximately 56'-0" from the south end of the wall, two 7 '-0" by 7 '-4" orenings located 5'-5" above the floor approximately 73'-0" and 84'-0" from the south end of the wall, and a 10'0" by 4'-8" pi pe penetratica opening covered with plywood located approximately l'-0" from the srth end of the wall.
6. There are louvered openings approximately 6'-0" deep between the turbine deck and the heater decks which open this zone to 1-TB-35-98. Thes e louvers run the full length of the heater decks.
7. Metal hatches provide connunication with the auxiliary feedwater pipe trench. No in-situ combustibles are located in the trench.
8. There is a metal hatch located in the ceiling of the west cable shaft (1-PB-14-25) which communicates with 1-TB-8-9A.
9. Concrete hatches are located in the ceiling of this zone communicating with the turbine deck,1-TB-35-98.
10. The boundary of the zone adjoining 1-TB-14-9E is a chain link fence,
11. Part of the south wall of the zone adjoining 1-TB-20-9D is chain link fence.

There are numerous small pipe and conduit penetrations in the walls which have not been called out because they are insignificant compared to the large openings.

Combustibles The in situ combustible loading in the turbine building ground floor is

approxima tely 110,000 Btu /sq.ft., with an equivalent fire severity of 82

! minutes. The in situ loading consists primarily of localized combustibles

! resulting from the lube oil within the lube oil reservoir at the north end of the zone, cable insulation located along the inside perimeter of the zone above the lube oil and chemical feed area and in the center of the zone, around the condensers and the hydrogen seal oil unit and several banks of batteries located in the south end of the zone.

l l Transient combustibles in the fire zone are insignificant relative to the

! overall fire loading for the fire zone.

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FIRE ZONE EVALUATION 1-TB-8-9A FIRE PROTECTION CAPABILITY Detection

! Four types of detectors are used to provide coverage of the hazards within the fire zone 1-TB-8-9A:

Cross-zoned infrared flame detectors are installed over the lube oil reservoir pump and conditioner areas.

- Infrared detectors are also installed at the hydrogen seal oil unit and over the emergency air compressor. -

- Line type heat detectors are installed in the cable trays above the lube oil reservoir area.

Ionization smoke detectors are installed at the lube oil reservoir area and at the south end of the turbine building near the exciter.

Su ppression Five automatic suppression systems are provided for the protection of the hazard areas within the fire zone:

- An automatic wet pipe sprinkler system is provided for the protection of the chemical feed area.

- An automatic wet pipe sprinkler system is provided for the protection of the chemical treatment area, the east wall and a portion of the south wall of the 480V switchgear room, the north wall of the chemical treatment area, and the structural steel at the north end of the fire zone.

- An aqueous film forming foam system is provided for the lube oil reservoir and conditioner areas. This system is actuated by the cross-zoned infrared detectors installed in this area.

- Automatic water spray systems protect the cable trays routed in the north portion of the fire zone near the lube oil and chemical feed areas. This system is actuated by line type heat detectors.

- An automatic water spray system, actuated by infrared detectors, is provided for the protection of the hydrogen seal oil unit at the south end of the turbine building.

Portable fire extinguishers and fire hose stations are available within the fire zone, and in adjacent fire area / zones for manual fire fighting capabilty.

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. ~.'. 4.s FIRE ZONE EVALUATION 1-TB-8-9A

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EVALUATION An evaluation is performed here to show that the criteria. of 10CFR50 Appendix R, Section III.G.3 are met with consideration given to the pending i request for exemption for this area. This _ evaluation demonstrates that the

fire zone boundaries will.contain a postulated fire and that the dedicated train of equipment located outside the fire zone is independent of the zone.

L The technical bases which justify the independence and' the ability to. perform the manual action necessary for safe shutdown are listed below:

1. The use of the dedicated shutdown (DSD) system is credited for a fire in this fire zone. >
2. Cables and equipment for the auxiliary shutdown' panel, C-38, have been t> relocated outside the fire zone. Panel C-38 will be physically located in ,

fire zone 1-YD-20-4G and used as the dedicated shutdown system panel.

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All dedicated shutdown system components will be located outside the fire j z one. Dedicated shutdown system components and circuitry are located independent of fire zone 1-TB-8-9A. The wall separating fire zone

l-TB-8-9A from the penetration area, fire zones 1-YD-20-4A and 1-YD-20-48, is 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> equivalent rated. Were the circuits for the DSD

! system are routed in fire zone 1-YD-14-4B they are provided with a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> fire rated barrier.

3. The dedicated auxiliary feedwater pump, the dedicated shutdown diesel and electrical systems, and the dedicated shutdown panel are located at the 4 - northwest corner of the yard area (1-YD-20-4G), and are independent from fire zone 1-TB-8-9A, due to the large spatial separation of approximately
100 feet, with isolated localized intervening combustibles.

! 4. The plant circuit breakers will be tripped in the control room to .,

deenergize offsite power and prevent and mitigate spurious equipment i o pera tion. The operation of the plant circuit breakers can be i accomplished at one panel, located near the control room exit, as the i operators evacuate the control room. Circuits for the ' manual trip of the i plant circuit breakers are routed outside this fire zone.
5. The charging pump used .for dedicated shutdown is located in the reactor auxiliary building lower level, zone 1-AB-(-3)-2A, and is independent i from fire zone 1-TB-8-9A due to the large spatial separation of i

j- approximately 100 feet with isolated localized intervening combustibles. i

! '6. The steam dump transfer control valve (SV-175) has been relocated from the mezzanine of the turbine building to the penetration area, 1-YD-20-43, where it is provided with a 3-hour rated barrier.

. 7. The esisting fire suppression and detection systems, provided for the i, significant combustibles within the fire zone provides protection a commensurate with the hazards within the fire zone. +

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FIRE ZONE EVALUATION 1-TB-8-9A

'8. To initiate single phase cooldown at approximately t=55 hours manual actuation of valves AFW-375 and 377, which are located near auxiliary feedwater pump G-10S will be required. Sufficient time is available a fter the extinguishment of the fire in 1-TB-8-9A to operate these valves.

9. The unsealed openings in the fire zone boundary do not affect the independence of the Dedicated Shutdown System as noted in items 2 and 3 above.
10. In addition to the safe shutdown circuits located in the fire areas / zones discussed above, the following operator actions may be required at emergency control stations outside this fire zone:

Operator action will be taken to manually control certain equipment that will either be independent of this fire zone or maintained free of fire damage in order to initiate dedicated shutdown system operation. The time required to perform the manual actions has been evaluated to assure adequate time and manpower will be available.

Operator action will be taken to manually close the reheater isolation valves, MOV-14,15,16 and 17, which are located within the fire area, after extinguishment of the fire. A study shows that these valves may remain open for up to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> without affecting the safe shutdown capability.

11. The San Onofre Fire Department consists of professionally trained full time personnel whose primary responsibility is fighting fires at San On o fre. The Fire Department is certified by the State of California Fire Marshall's office to provide fire suppression activities. A minimum of five certified fire fighters are on duty per shift. The first arriving fire fighters under normal circumstance can be expected to be on scene within five minutes of the receipt of the alarm.

CONCLUSION The suppression and detection provided for the zone is adequate for the fire hazards present. Independence of the dedicated shutdown system is maintained by a combination of spatial separation and fire rated barriers. There fore ,

the installation of additional fire detection or fixed automatic fire suppression systems to provide coverage throughout the fire zone would not enhance, to a significant degree, the protection of safe shutdown functions.

Therefore, it is concluded that fire zone 1-TB-8-9A is in compliance with the requirements of 10CFR50 Appendix R, Section III.G.3 with consideration given to the pending exemption.

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  • e FIRE ZONE EVALUATION 1-TB-35-98 TITLE: Turbine Deck FIGURE: 3-2 INTRODUCTION This evaluation is provided to demonstrate compliance with 10 CFR 50 Appendix R, Section III.G.1 by demonstrating that for a fire in fire zone l-TB-35-98, the redundant cables and components outside the fire area will remain free of fire damage. This evaluation also includes justification to demonstrate compliance with 10 CFR 50 Appendix R Section III.G.3 by demonstrating that the alternate shutdown capability is independent of the fire zone. The redundant trains of the primary system hot leg temperature transmitters and the pressurizer pressure transmitters are within this fire zone. 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. Al ternative ,

pressurizer pressure indication is available at the dedicated shutdown panel.

AREA DESCRIPTION Physical Characteristics The turbine deck is an exterior fire zone, which consists of the feedwater heater deck, located at elevation 35', and the turbine deck, located at elevation 42' . The walls separating the zone from the control room complex (1-PB-42-16) are 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated. The north end of the zone adjoins the steel containment sphere. The renainder of the walls separating the zone from other fire areas are reinforced concrete or concrete block, with a minimum thickness of 8 inches. The floor of the zone is reinforced concrete.

1 This zone has the following unsealed openings:

1. There are louvered ventilation openings at the feedwater heater decks communicating with the turbine building ground floor, zone 1-TB-8-9A.
2. There are louvered ventilation openings on the west side communicating wi th area 1-FH-42-6.

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3. There is a nonrated steel personnel access hatch and a nonrated steel equipment access hatch opening to area 1-C0-(-10)-1, located on the north end.
4. There is a nonrated sliding steel door and a nonrated rolling metal door communicating with area 1-FH-2-5, located at the west side of this tone.
5. There is a nonrated rolling metal door opening to area 1-FH-42-6, located at the west side of this zone.

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FIRE ZONE EVALUATION 1-TB-35-98

6. Concrete hatches are located in the reheater floor areas communicating with the turbine building-ground floor,1-TB-8-9A.
7. The zone opens to the penetration area,1-YD-20-4A and 1-YD-20-4B.
8. Numerous unsealed pipe and conduit penetrations pass through the floor to the turbine building ground flocr,1-TB-8-9A.

Combustibles The in situ combustible loading'on the turbine deck is approximately 114 Btu /sq.ft., with an equivalent fire severity of under one minute. The in situ loading consists of oil and grease from the turbine lube oil system and the overhead crane.

FIRE PROTECTION CAPABILITY Detection No detection is installed in this fire zone.

Suppression Portable fire extinguishers and six fire hose stations are available within the ' fire zone for manual fire fighting capability.

EVALUATION An evaluation is presented here to demonstrate that the fire zone boundary will contain a postulated fire so that the redundant train of equipment will be free of fire damage (per Section III.G.1 of Appendix R) and that the alternate train of equipment located outside the fire zone is independent of the zone (per Section III.G.3 of Appendix R). Also, this evaluation demonstrates that necessary manual actions can be taken in a timely manner.

The technical bases which justify the separation and the ability to perform the manual actions necessary for safe shutdown are listed below:

1. Circuits for the following control room instruments are routed in this fire zone: TE-2401 A, 2412A, 2422A, TE-3402A, 3411 A, 3421 A, PT-425 and LT-3400A, B and C. Alternative shutdown capability is provided by using dedicated shutdowa system ins trumentation, (TE-402A, 412A, 422A and PT-434A) which are routed in fire zone 1-YD-20-4G, which has a minimam separation, with no intervening combustibles, of 40 feet and fire zone l-YD-20-4B where these circuits are provided with a 3-hour rated barrier. Redundant control room ins truments (LT-2400A, B, C TE-400A, TE-4000 and TE-410A, TE-412C and TE-402A, TE-4200) are also available and are routed in adjacent fire areas / zones 1-PB-42-16,1-YD-20-4A, 1 - YD-20-4B , and 1-TB-8-9A.

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, s I FIRE ZONE EVA:.UATION 1-TB-35-98

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2. Pressurizer pressure transmitters PT-430'and PT-431 in this zone could cause spurious operation of pressurizer heater groups A and B and 3

pressurizer PORV, CV-546. To prevent these spurious actions, pressurizer

heater groups A and B, and PORV CV-546 or block valve CV-530 can be tripped from the control roon and left in the trip position.. The i circuits for the redundant pressurizer heater groups C & D and PORY block valve, CV-530, are located in adjacent fire zones 1-YD-20-4A, .1-YD-20-48, 1-TB-8-9A and 1-YD-14-4D (all located below the subject fire zone).

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L 3. Damage to cables for the thermal barrier pump could cause the loss of I remote control of the pump. The component cooling water pump circuits are routed outside this fire zone, in adjacent fire zones 1-YD-20-4A, l l-YD-20-48,1-YD-14-40 and 1-TB-8-9A. The circuits in fire zone ll l-YD-20-4A,1-YD-20-4B and 1-TB-8-9A are below 1-TB-35-9B and shielded by

! the floor of the turbine deck. 1-YD-14-4D is adjacent to and 15' below the turbine deck. Due to their orientation, demanding that the fire 4

propagate downward and the fact that these adjacent zones are located below the turbine deck, a fire in 1-TB-35-98 is not expected to affect j the adjacent areas.

4. Circuits for diesel generator 2 are routed in the fire zone. Redundant i diesel generator I circuits routed in adjacent ' fire area 1-PB-42-16 are separated by 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> barriers and therefore will remain free of fire
damage.

i 5. Fire in this area will not propogate to adjacent areas / zones because of the following:

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Minimal fire loading in 1-TB-35-9B prevents large fires, i

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  • Combustible gases and heat generated by a fire in the zone would be

! dissipated to the atmosphere.

l Fire is not likely to propagate vertically downward 15 to .!0 feet to i the remainder of fire area 1-TB-8-9 or fire zones 1-YD-14-40, 1-YD-20-4A and 1-YD-20-48.

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6. Adjacent fire areas 1-FH-2-5 and 1-FH-42-6 with which this zone j tommunicates contain no safe shutdown equipment l 7. The in-situ combustible loading in the fire area results in an equivalent

! fire severity of under one minute.

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8. Codustible gases and heat generated by a fire in the zone would be j dissipated to the atmosphere.
9. Portable fire extinguishers and fire hose stations are immediately available for manual fire fighting purposes.

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FIRE ZONE EVALUATION 1-TB-35-98

10. The circuits associated with PV-1611,1612,1650 and 1651 are located at the north end of the high pressure turbine in the vicinity of the turbine s tand . If for some reason the manual trip could not be achieved due to inaccessibility due to the fire, the turbine could still be tripped by tripping the generator from the control room and allowing the turbine to trip on overspeed which again relies on no electrical device once the generator is tripped.

i 11. In addition to the safe shutdown circuits located in the fire areas / zones ,

discussed above, the following operator actions may be required at emergency control stations outside this fire area:

Fire damage to cables for the AFW turbine steam supply valve, -

CV-3201, and the steam driven AFW pump service water supply valve, 1 SV-3205, could cause spurious operation of the:;e valves and the loss of use of the steam driven AFW pump, G-10. Circuits for redundant motor driven AFW pump, G-10S, and discharge valve MOV-1202, would also be lost. Operator action will be required to deenergize and manually open MOV-1202 and start pump G-10S at the 480VAC switchgear 1 in fire area 1-PB-14-8.

Isolate instrument air and manually position AFW control valves FCV-2300, 2301, 3300, & 3301 in fire zone 1-YD-14-4D. .

Close reactor vessel vent valve SV-3402 and pressurizer high point vent valve SV-3404 at disconnect switches which will be installed at the penetration area in 1-YD-20-4A and 1-YD-20-43.

Verify closed AFV bypass isolation valve MOV-1204 in 1-TB-8-9A.

The time required to perform the manual actions has been evaluated to assure adequate time and manpower will be available,

12. The San Onofre Fire Department consists of professionally trained, full time personnel whose primary responsibility is fighting fires at San Ono fre. The Fire Department is certified by the State of California Fire Marshall's office to provide fire suppression activitias. A minimum of five certified fire fighters are on duty per shift. The first arriving fire fighters under normal circumstances can be expected to be on scene within five minutes of the receipt of the alarm.

CONCLUSIONS Based on the above described configuration of the fire zone, the low fire loading, and the available path for dissipation of the heat and products of combustion resulting from the fire to the atmosphere, this evaluation demonstrates that one train of redundant equipment necessary to achieve and maintain hot standby and cold shutdown from the control room and the emergency 4

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FIRE ZONE EVALUATION 1-TB-35-9B control stations will remain free of fire damage, and the equipment used to provide alternate shutdown capability is independent of the fire zone. This evaluation demonstrates that fire zone.1-TB-35-98 is in compliance with the requirements of 10 CFR 50 Appendix R, Section III.G.1, and with 10 CFR 50 Section III.G.3 with consideration given to the pending exemption.

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FIRE AREA EVALUATION 1-PB-20-Il and 1-PB-20-12 TITLE: Office / Health Physics and Locker Room, Equipment Room, Counting Room, Communications Room and Radioactive Material Storage Room FIGURE: 3-1, 3-2 INTRODUCTION s This evaluation is provided to demonstrate compliance with 10CFR50 Apendix R,Section III.G.1 by demonstrating that for a fire in 1-PB-20-ll and 1-PB-20-12 the redundant cables and components outside this area will remain free of fire-damage. For the purpose of this evaluation, fire areas 1-PB-20-Il and 1-PB-20-12 will be considered one combined fire area.

One train of cables for the redundant component cooling water pumps G-15A, B and C (located in fire areas / zones 1-YD-20-4B,1-FH-14-7,1-PB-14-8, 1-TB-8-9A,1-YD-20-4D, and 1-PB-42-16) must be shown to be free of fire damage in the event the control cable to pump G-964 (the thermal barrier pump) located in the combined fire area is lost. The redundant diesel generator system circuits (DG train e located in fire zones 1-DG-20-17A and 1-DG-20-17B) must also be shown to be functional in the event the DG train 1 circuits in the combined fire area are lost.

Backup power to DC Bus 1 and to the vital buses 1, 2, 3 and 3A must be shown to be available following loss of circuitry for battery charger D02 and 120 VAC power. Redundant equipment for the train 1 battery charger is located in fire areas 1-DG-20-17 and 1-DG-20-18. Circuits for backup power to the vital buses are located in fire area / zones 1-YD-20-4A,1-YD-20-48,1-FH-14-7, 1-PB-14-8,1-TB-8-9A,1-TB-35-98,1-PB-42-16 and 1-PB-56-33. These fire areas / zones must be shown to be free of fire damage in the event of a fire in the combined fire area.

AREA DESCRIPTION Physical Description Fire areas 1-PB-20-ll and 1-PB-20-12 are located in the Power Block Building at elevations 20'-0" and 32'-0". Fire area 1-PB-20-Il is an "L" shaped area adjacent to the 4160V switchgear room, bordering it on the north and east.

The area is made up of one fire zone at elevation 20' (1-PB-20-ll A, Health Physics and Locker Room) and four fire zones on the floor above (1-PB-32-llB, HVAC Equipment Room; l-PB-30-llc, Counting Room; l-PB-30-llD, Communications Room; and 1-PB-30-IIE, Radioactive Material Storage Room). Fire area 1-PB-20-12 (Office) is north and east of 1-PB-20-11. Because the barrier between the two fire areas has unsealed penetrations and the single cable tray containing safe shutdown circuits is located in both areas, the areas are evaluated as a single combined fire area.

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FIRE AREA EVALUATION 1-PB-20-11 and 1-PB-20-12 The east and north boundaries of the combined fire area border on the open area in the front of the power block. These walls are non-rated, but because the open area outside has no power plant equipment, any potential propagation of fire is of no concern to safe shutdown equipment. The south boundary of the combined area, at elevation 20, is a 1-hcur rated barrier providing separction from fire area 1-PB-20-13. The west boundary adjoins fire zone 1-PB-14-9E and is separated by a non-rated reinforced concrete wall. The west boundary also includ s a 3-hour rated wall providing separation from 1 - PB-14-8. The north boundary of the combined fire area borders on 1-YD-20-4A (east penetration zone) and 1-YD-14-4D (yard zone). Reinforced concrete walls provide separation at these northern boundaries. The boundary with the 1-PB-42-16 (control room) above is a fire rated reinforced concrete floor slab.

Other boundaries of the combined fire area include reinforced concrete walls which border the open area above the roof of 1-PB-20-12 and the fire rated walls which provide separation from fire areas 1-PB-20-29 and 1-PB-20-31 (the north and south stairwells).

The combined fire area has the unsealed or non-rated openings identified below which adjoin adjacent fire areas and could potentially allow fire spread.

Unsealed openings into areas without safa shutdown equipment and which will not contribute to fire spread are not addressed.

Fire area 1-PB-20-12 has 12" x 12" and 8" x 8" duct openings to the roof above and a 1-1/2" pipe penetration through a 2-1/2" core bore.

Fire zone 1-PB-32-11B has a 14" x 24" duct opening up to the roof (1-PB-56-33).

The north wall of fire area 1-PB-20-Il a conduit penetrating an individual core bore without a rated seal (bordering 1-YD-14-4D).

The door between 1-PB-20-ll A and 1-YD-20-4A is a non-rated steel door.

The door from 1-PB-32-llB to the outside area above 1-TB-14-9E is no n-ra ted.

Ventilation duct penetrations adjacent to the non-rated door above 1-TB-14-9E is not provided with fire damper.

Combustibles The combustible loading for the fire area is primarily Class A combustibles representing the paper stored in the office areas. The combustibles in the combined fire area represent a design basis fire of .38 hour4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br />. The design basis fires in zones 1-PB-20-ll A and 1-PB-32-llB, which are the only zones which could communicate with other plant fire areas having safe shutdown equipment, are an equivalent .11 hour1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> and .08 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> fires respectively.

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FIRE AREA EVALUATION 1-PB-20-ll and 1-PB-20-12 FIRE PROTECTION CAPABILITY Detection Fire area 1-PB-20-ll has local ionization detection in zone 1-PB-20-ll A, zone-wide detection in the other zones except 1-PB-30-llE which has no detection. Fire area 1-PB-20-12 has local ionization detection above and below the false ceiling in the vicinity of the single cable tray )ith the safe

hutdown circuitry.

Suppression Portable fire extinguishers and hose stations are provided in this combined fire area.

EVALUATION An evaluation is performed to show that the criteria of 10 CFR 50 Appendix R, Section III.G.1 are met. This evaluation demonstrates that the combined fire area (1-PB-20-li and 1-PB-20-12) will contain a postulated fire and that the redundant train of required safe shutdown equipment will remain free of fire damage. The technical bases which justify the adequacy of the existing separations are listed below:

1. The circuits for component cooling water pumps G-15A, -15B and -15C loca ted in fire area / zones 1-YD-20-48,1-FH-14-7,1-PB-14-8,1-TB-8-9A, 1-YD-20-40 and 1-PB-42-16 will be free of fire damage, therefore operation of the thermal barrier pump, 3-964, is not required.

Additionally, the circuits for backup power to Vital Buses 1, 2, 3 and 3A are located in fire area / zones 1-YD-20-4A,1-YD-20 48,1-FH-14-7, 1-PB-14-8,1-TB-8-9A,1-TB-35-98,1-PB-42-16 and 1-PB-56-33 which will also be free of fire damage for the following reasons:

- 3-hour rated barriers separate the combined area from 1-PB-14-8 and 1-PB-42-16

- 1-hour rated barrier separates the combined area from 1-PB-20-13; this boundary has been previously accepted by the NRC as documented in the Fire Protection SER.

The only nonrated concrete construction with penetrations adjacent to fire area 1-TB-8-9 occurs at the door / filter at elevation 32',

which is 18' above the fire zone 1-TB-14-9E. This zone has no redundant safe shutdown equipment and is isolated from the remainder of fire area 1-TB-8 9 by a 24' open space which is free of intervening combustibles. Additionally, a fire in the region of the door / filter will not propagate downward to adjacent fire zone 1-TB-14-9E because there are no combustibles in the vicinity of the door / filter and zone 1-TB-14-9E is outside.

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FIRE AREA EVALUATION 1-PB-20-11 and 1-PB-20-12 The fire duration in 1-PB-20-ll A, which is 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, represents the major potential hazard to adjoining fire zones 1-YD-20-4A and 1 - YD- 14-4 D . The fire is of sufficiently short duration that the non-rated metal door in the barrier with 1-YD-20-4A should adequately contain the fire. Also, the distance from the door to the closest in situ combustible is approximately 20' horizontally and 20' vertically and the fire area itself is basically outside.

Therefore, fire is not likely to propagate from 1-PB-20-Il to 1 - YD- 20-4 A.

Additionally, the reinforced concrete walls separating 1-PB-20-ll from 1-YD-14-40, is a heavy concrete wall with a few unsealed conduits in an individual close-fitting core bores. This barrier will provide an effective fire barrier because of the fire duration and the fact that there is no path for smoke or flames to pro pa ga te. The yard area outside the wall is basically free of combustibles. A station transformer sitt approximately 5' from the wall, but is protected by an automatic deluge system. The only other combustibles in this outside area are two small covered cable tra ys . Separation between the barrier and redundant equipment, which is west of the turbine building is well in excess of 100' including 40' without intervening comoustibles.

The Power Block roof (1-PB-56-33) communicates with zone 1-PB-32-llB, 24 feet below, through a vertical metal duct. Due to the short fire duration (.08 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) fire propagation to the roof is unl ikely.

Fire area 1-FH-14-7 is separated by rated fire barriers.

Fire zone 1-YD-20-4B is separated from the combined area by outside areas with regions of no intervening combustibles up to 40' in width (at the interface of zones 1-YD-20-4A and 1-YD-20-48).

, 2. Redundant diesel generator 2 circuits (located in fire area 1-DG-20-17, which is a separate building with reinforced concrete walls) will remain available if circuits for diesel generator 1 are damaged. The redundant diesel generator 2 circuits are routed from the diesel generator building 1-DG-20-17 to the 4160 volt switchgear room 1-PB-14-8 via underground duct banks and in the following additional fire zones: 1-YD-20-4A,

. 1-PB-42-16,1-PB-56-33 and 1-TB-35-9B. The potential for propagation of fire to these additional zones has been evaluated in item 1 above.

3. Backup power to DC Bus 1 will remain available from battery 1 (located in 1-PR-20-13) i f cables to battery charger 002 are damaged.

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FIRE AREA EVALUATION 1-PB-20-ll and 1-PB-20-12

4. The following adjacent fire areas / zones do not contain safe shutdown equipment or cables:

1 - PB-35-15 TSC HVAC Room 1 - PB-20-2 9 North Stairway 1 - PB-42-30A Chemistry 1 - PB-42-308 Radiochemical Laboratory 1 - PB-20-31 B Stairway / Locker Room

5. In addition to the safe shutdown circuits located in the fire areas / zones discussed above, the following operator actions may be required at emergency control stations in fire areas / zones outside the combined area:

A cable associated with charging pump flow control valve, FCV-lll2, is routed in the combined area. Failure of this cable could cause FCV-Ill2 to fail closed. For higher makeup flow rates through charging loop A, FCV-Ill2 control will be captured at panel C-38 in fire zone 1-YD-20-4G and the valve regulated to the desired fl owra te.

Operator action would be taken to manually trip the turbine at the turbine stand on the turbine deck (1-TB-35-9B) due to the potential loss of circuits associated with remotely tripping the turbine from the control room which are routed through this area.

The availability of steam dump control through the positioner located in the control room (fire area 1-PB-42-16) would mitigate the loss of remote control to the atmospheric steam dump valves.

6. The San Onofre Fire Department consists of professionally trained, full-time personnel whose primary responsibility is fighting fires at San Ono fre. The Fire Department is certified by the State of California Fire Marshall's office to provide fire suppreston activities. A minimum of five certified fire fighters are on duty per shift. The first arriving fire fighters under normal circumstances can be expected to be on scene within five minutes of the receipt of an alarm.

CONCLUSION Based on the above described configuration qf the fire area, and the detection capability provided, this evaluation demons trates that one train of systems necessary to achieve and maintain hot standby end cold shutdown from the control room and emergency control stations, will remain free of fire damage.

This evaluation demonstrates that the combined fire area 1-PB-;0-Il and 1-PB-20-12 meets the requirements of and is in compliance with 10 CFR 50 Appendix R, Section I!!.G.I .

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r-

.P ,

FIRE AREA EVALUATION 1-PB-20-13 TITLE: DC Switchgear and Battery Rooms Figure: 3-1 INTRODUCTION This evaluation is performed to demonstrate compliance with 10CFR50 Appendix R.

Section III.G.1 by demonstrating that for a fire in fire area 1-PB-20-13 DC Switchgear and Battery Rooms, the redundant cables and components outside this fire area will remain free of fire damage. Circuitry associated with the following equipment is located in fire area 1-PB-20-13: diesel generator train 1,120VAC dis tribution panel s Y-11, Y-12, Y-13 and Y-33, inverters 1, 2, 3 and 4,125VDC bus 1, battery chargers 002 and 003, battery D04, RPS trip circuits and thermal barrier pump, G-964. Redundant components and circuitry for the above equipment is routed through non-adjacent fire areas as discussed below.

AREA DESCRIPTION Physical Characteristics Fire area 1-PB-20-13 is located at the south end of the power block building.

The fire area is comprised of fire zones 1-PB-20-13A (DC switchgear roem),

1-PB-20-138 (battery room), and 1-PB-29-13C (battery room attic, above 1 - P3-20-13B ) . The north wall of fire area 1-PB-20-13 adjoins fire areas / zones 1-PB-20-12 and 1-PB-20-31B and is a 1-hour rated fire barrier. The east wall ,

adjacent to the exterior is nonrated concrete. The ceiling, south wall (forming the exterior), and the west wall (adjacent to fire zone 1-TB-14-9E) are of non-rated reinforced concrete construction. The floor is concrete slab on grade.

The area has the following non-rated penetrations:

1. The west wall contains a 2'0" by 2'0" ventilation duct to the exterior, located 7'6" above the floor near the south wall. A steel plate covers an unsealed penetration.
2. The west wall (adjacent to 1-TB-14-9E) contains an unsealed cable tray pene tra tion.
3. The south and east walls, both adjacent to the exterior, contain several nonrated penetrations. The exterior areas do not contain any safe shutdown circuits, therefore, the fire integrity of the south and east walls is not addressed for this evaluation.

Combustibles The in situ combustible loading in this fire area consists of cable, Class A combustibles, plastics, and a small amount of miscellaneous combustibles located throughout the fire area. There are also four banks of batteries 368th:6856F8529u Revision 1

FIRE AREA EVALUATION 1-PB-20-13 located along the east wall. The combustible loading is 47,014 BTU /sq. ft.

with an equivalent fire severity of 37 minutes. The batteries would account for 7 minutes of the fire, while the other combustibles would account for the remaining 30 minutes of fire duration.

Due to the nature of the equipment located in the area, no significant quantities of transient combustibles are expected to be found therein.

FIRE PROTECTION CAPABILITY Detection There are three ionization smoke detectors providing partial protection for the area. The detectors provide adequate fire detection for the loading of combustibles in the room.

Suppression There are portable extinguishers in adjacent fire areas / zones (1-PB-20-12 &

1-PB-20-31B).

EVALUATION An evaluation is performed to show that the criteria of 10CFR50, Appendix R, Section III.G.1 are met. This evaluation demonstrates that the fire area boundaries will contain a postulated fire and that the redundant train of required safe shutdown equipment will remain free of fire damage. The technical bases which justify the adequacy of separation are detailed below:

1. The wall separating 1-PB-20-13 from 1-PB-20-31B and 1-PB-2012 is a i-hour fire rated wall containing only raceway penetrations with fire rated seals.
2. The west wall, separating 1-PB-20-13A from 1-TB-14-9E, is constructed of reinforced concrete with a ncnrated raceway seal and ventilation openin g. The unsealed duct penetration in the west wall, adjoining the ramp area (1-TB-14-9E), will not support the propagation of a fire into the ramp area as there are no combustibles in the immediate vicinity of the penetrations, except for a cable tray located a horizontal distance of 7'-6" from the nearest ventilation opening. It is unlikely that the cable tray would be damaged because heat and the products of combustion would rise to the atmosphere.
3. Train 1 batteries are located in fire zone 1-PB-20-138. The train 2 batteries are located in fire zones 1-DG-20-17A and 1-DG-20-17B (diesel generator building). The separation between the two battery banks consists of the entire fire area 1-PB-20-12, and the eastern portion of the yard ,1-YD-14-40. It is unrealistic to postulate that a fire 3681h:6856F8529u Revision 1

FIRE AREA EVALUATION 1-PB-20-13 damaging the train 1 batteries in 1-PB-20-13 could damage the train 2 batteries in 1-DG-20-17A and 1-DG-20-17B due to the large spatial separation between the diesel generator and power block buildings. 'The closest train 2 battery circuitry to the subject fire area is located in fire area 1-PB-14-8 (4kV switchgear room). Fire area 1-PB-14-8 is not adjacent to the subject fire area, and it is surrounded by a three hour rated fire barrier. It is unlikely that any fire damaging the train 1 batteries located in 1-PB-20-13 could damage the train 2 circuitry in 1-PB-14-8 due to the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated fire barrier.-

4. Circuits associated with diesel generator train 1 are located in fire area 1-PB-20-13. Diesel generator train I circuits are contained in a single, partially covered cable tray (61L1) penetrating the wall between 1-PB-20-13A and 1-TB-14-9E. The tray traverses along the reinforced concrete wall and into fire area 1-PB-14-8. Fire zone 1-TB-14-9E is open to the outdoors, permitting a very rapid dissipation of heat from a fire to the atmosphere. The fire loading in zone 1-TB-14-9E consists of cable trays representing a combustible loading of 802 Btu /sq ft. for an equivalent fire severity of less than one minute.

There are no redundant diesel generator train 2 circuits located in 1-PB-20-13 or adjacent areas zones 1-PB-20-12,1-PB-20-31B,1-PB-20-11 A, or 1-TB-14-9E. The nearest train 2 essential electric system circuits are located in fire zone 1-TB-8-9A, opproximately 50 feet west of the subject fire area, including 24 feet free of intervening combustibles.

5. The cables for thermal barrier pump (G-964) are rooted in the subject fire area. The redundant cables for component cooling water pump (G-15A) are routed in fire areas / zones 1-TB-8-9A,1-FH-14-7,1-PB-14-8, 1 -YD-14-40,1-YD-20-4B a nd 1-PB-42-16. The circuits for redundant pump (G-15A) in 1-TB-8-9A are located over 70 feet from fire area 1-PB-20-13.

The north end of 1-TB-8-9A contains automatic suppression and detection  ;

systems providing protection of circuits for redundant pump G-15A.

6. Circuits associated with the 120VAC distribution panels Y-ll, y-12, Y-13 .

and Y-33 and inverters 1, 2, 3 and 4 are located in fire area 1 - PB-20-13. Loss of these circuits result in the loss of the 120VAC distribution panels, however, backup power is available from MCC-2. i Circuits for this backup power are routed through non-adjacent fire i arns/ zones 1-FH-14-7,1-PB-14-8,1-TB-8-9A,1-PB-42-16. There fore ,

these distribution panels will remain available.

7. Equipment and cables associated with the 125VDC bus 1 (001) and battery chargers (D02 and D03) are located in fire area 1-PB-20-13. Redundant DC l bus 2 components and cables are located in non-adjacent fire areas 1-DG-20-17 and 1-DG-20-18.

[ 8. Damage to the RPS circuits, caused by a postulated fire, could result in

a reactor scram. This would not affect the ability to safely shut the plant down.

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~

FIRE AREA EVALUATION 1-PB-20-13

9. The following adjacent fire areas / zones do not contain safe shutdown equipmer t or cables:

1-PB-20-318 Stairway / locker room 1-PB-35-15 TSC HVAC Room

10. In addition to the safe shutdown circuits located in the fire areas / zones discussed above, the following operator actions may be required at emergency control stations outside the subject area:

A cable associated with charging pump flow control valve, FCV-1112, is routed in 1-PB-20-13. Failure of this cable could cause FCV-lll2 to fail closed. For higher makeup flow rates through changing loop A FCV-Ill2 control will be captured at panel C-38 in fire zone 1-YD-20-4G and the valve regulated to the desired flow ra te.

Circuits for the turbine stop valve actuators, PV-1611 and PV-1612, are routed in the subject area. If damage occurs to the circuits, a manual trip located at the turbine stand in fire zone 1-TB-35-98 may be actuated. This manual trip is located over 80 feet from the subject fire area with at least 24 feet of no intervening combustibles.

Cables for the quick-open operation of the atmospheric steam dump valves are routed in this area. The steam dump control through the positioner located in the control room (fire area 1-PB-42-16) would remain available.

11. The San Onofre Fire Department consists of professionally trained full time personnel whose primary responsibility is fighting fires at San Ono fre. The Fire Department is certified by the State of California Fire Marshall's office to provide fire suppression activities. A minimum of five certified fire fighters are on duty per shift. The first arriving fire fighters under normal circumstance can be expected to be on scene within five minutes of the receipt of the alarm.

CONCLUSIONS Based on the above described configuration of the fire area, the low combustible loading, and the spatial separation of the redundant equipment, one train of systems necessary to achieve and maintain hot standby and cold shutdown from the control room and the emergency control stations, will remain free of fire damage. This evaluation demonstrates that fire area 1-PB-20-13 meets the requirements of, and is in compliance with,10 CFR 50 Appendix R.

Section III.G.I .

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ll FIRE AREA EVALUATION 1-PB-14-25 TITLE: West Cable Shaft FIGURE: 3-1 INTRODUCTION This evaluation is provided to demonstrate compliance with 10CFR50 Appendix R, Section III.G.1 by demonstrating that for a fire in 1-PB-14-25 the redundant cables and component; outside this area will remain free of fire damage.

1-PB-14-25 contains circuits for diesel generator train 1. Adjacent fire area 1-PB-14-8 contains redundant diesel generator circuits. Fire zone 1-TB-8-9A contains redundant train 2 essential electric distribution system (ESDS) circuits.

AREA DESCRIPTION Physical Characteristics The west cable shaft, fire area 1-PB-14-25, is located in the power block building adjacent to fire arear.1-PB-14-8 (4kV switchgear room), fire area 1-PB-14-26 (east cable shaft), and fire zone 1-TB-8-9A (turbine building ground floor). The wall separating fire area 1-PB-14-25 from 1-PB-14-8 is a 3-hour rated fire barrier. The remaining walls of 1-PB-14-25, adjoining fire area 1-PB-14-26 and fire zone 1-TB-8-9A, are constructed of 18" thick reinforced concrete.

This area contains the following nonrated penetrations:

1. A 3/8" steel hatch is located in the ceiling of this area which provides access between this area and zone 1-TB-8-9A.

Combustibles The in-situ combustible loading in fire area 1-PB-14-25 consists of approximately 700 pounds of cable. The fire loading is 270,614 BTV/sq.ft.,

with an equivalent fire severity of 3.38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br />.

The fire loading shown above presents a distorted view of the combustible loading because this area is a vertical cable chase with a very small floor area relative to its height. The quantity of cable insulation called out above is based on 30% fill by volume. For cable trays that are more the 30%

full, the actual pereentage fill has been used. This is extremely conservative, since very few trays are filled to greater than 30% and the actual plant average tray fill is significantly lower.

_ Due to the remote location and confined nature of the area, insignificant quantities of transient combustibles are expected.

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, .I FIRE ARE A EVALUATION 1-PB-14-25 FIRE PROTECTION CAPABILITY Detection There is one ionization smoke detector located on the ceiling of the cable shaft.

Su ppression There are portable extinguishert. and manual hose stations located in adjacent areas 1-PB-14-8 and 1-TB-8-9A w'iich are available for fire suppression activities.

EVALUATION An evaluation is performed to show that the criteria of 10CFR50, Appendix R.

Section III.G.1 are met. This evaluation demonstrates that the fire area boundaries will contain a postulated fire and that the redundant train of required safe shutdown equipment will remain free of fire damage. The technical bases which justify the adequacy of separation are detailed below.

1. Fire area 1-PB-14-25 contains only diesel generator (DG) train 1 circuits. Train 2 ESDS circuits are located in adjacent fire area 1-PB-14-8 and fire zone 1-TB-8-9A. The nearest train 2 ESDS circuits are located in fire zone 1-TB-8-9A, approximately 15 feet below the top of the hatch and approximately 10 feet to the west of the cable shaft. The 3/8" hatch is designed to stay firmly in place and would reduce the exposure to the spread of fire. There are no combustibles above the h a tch. In the unlikely event that the hatch failed, the chimney effect and thermal column created by the fire would carry the products of combustion, heated gases, and flame upward into the open atmosphere.

Train 2 ESDS circuits will remain free of fire damage in the event that DG train 1 cables are damaged by a fire in this fire area.

2. Adjacent fire are 1-PB-14-8 is separated from this fire area by a 3-hour rated wall .
3. In addition to the safe shutdown circuits located in the fire area / zones discussed above, the following operator actions may be required at emergency control stations in fire areas / zones outside the area:

A cable associated with charging pump flow control valve, FCV-lll2, is routed in area 1-PB-14-25. Failure of this cable could cause FCV-lll2 to fall closed. For higher makeup flow rates through charging loop A FCV-lll2 control will be captured at panel C-38 in fire zone 1-YD-20-4G and the valve regulated to the desired flowrate.

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...b FIRE AREA EVALUATION 1-PB-14-25

4. The San Onofre Fire Department consists of professionally trained full-time personnel whose primary responsibility is fighting fires at San Ono fre. The Fire Department is certified by the State of California Fire Marshall's office to provide fire suppression activities. A minimum of five certified fire fighters are on duty per shift. The first arriving fire fighters under normal circumstances can be expected to be on scene within five minutes of the receipt of the alarm.

CONCLUSION Based on the above described configuration of the fire area, the resistance to the propagation of the fire provided by the metal hatch cover, the lack of combustibles in the immediate vicinity of the hatch, and the spatial separation of the redundant equipment, this evaluation der.anstrates that one train of systems necessary to achieve and maintain hot standby and cold shutdown from the control room and the emergency control stations, will remain free of fire damage. This evaluation demonstrates that fire area 1..PB-14-25 meets the requirements of, and is in compliance with 10 CFR 50 Appendix R, Section III.G.I .

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FIRE AREA EVALUATION 1-PB-56-33 TITLE: Power Block Building Roof FIGURE: 3-2 INTRODUCTI0st:

This evaluation is provided to demonstrate compliance with 10CFR50 Appendix R, Section III.G.1 by demonstrating that for a fire in 1-PB-56-33 the redundant cables and components outside the fire area will remain free of fire damage.

This evaluation also includes justification to demonstrate that the alternate shutdown capability is independent of the fire area in accordance with 10 CFR 50, Appendix R, Section III.G.3.

Fire area 1-PB-56-33 contains circuits for RCS temperature (TE-2401 A, 2412A, 2422A, 3402A, 3411 A, 3421 A), RC5 pressure (PT-425, PT-430 PT-431), steam generator level (LT-3400A, B, C) and diesel generator train 2. Circuits for redundant or alternate safe shutdown components tFat are routed in adjacent fire areas are discussed below to demonstrate their availability following a fire in 1-PB-56-33.

AREA DESCRIPTION Physical Characteristics This fire area consists of the power block roof at elevation 56', and is located directly above the control room. The roof is constructed of reinforced concrete with a minimum thickness of 7-1/2 inches. The roof slab is covered by built up roofing on 1/2 inch insulation. The area is accessed via a ladder on the east side of the power block roof.

This area has the following uasealed openings

i 1. A 24" X 24" ventilation duct in the floor communicating with 1-PB-32-118 is not provided with a fire damper.

2. Exhaust fan EF-7 communicates with 1-PB-42-308 is not provided with a fire damper.

Combustibles The in situ combustibles are limited to the roofing materials.

Due to the fire area's remote location, no significant transient combustibles are expected.

FIRE PROTECTION CAPABILITY Detection There is no fire detection equipnent installed in this area.

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t FIRE AREA EVALUATION 1-PB-56-33 Suppression ,

-A portable fire extinguist.er is available on the power block roof for manual fire fighting capability. Additional manual fire fighting capability is available from the fire department portable equipment.

EVALUATION:

An evaluation is presented here to demonstrate that the fire area boundary

. will contain a postulated fire so that the redundant train of equipment will

be free of fire damage (per Section III.G.1 of Appendix R) or alternate trains of equipment (per Section III.G.3 of Appendix R) is located independent of the l' fire area and. demonstrate that manual actions can be taken in a timely mann er. The technical bases which justify this credit and the ability to perform the manual actions necessary for safe shutdown are listed below:
1. Cables for the following control room primary system hot leg temperature instruments TE-2401 A, 2412A, 2422A, TE-3402A, 3411 A, 3421 A are roated in
this fire area. Should a fire occur on the power block roof, alternative shutdown capability is provided by using the following instrumentation on the dedicated shutdown panel (TE-402A, TE-412A and TE-422A). Circuits for the instruments on the dedicated shutdown panel are not routed in adjacent fire areas and are crnsidered to be independent of the fire i area. In addition, alternate hot leg indication is available in the control room through the use of the primary system delta T instruments (TE-400A, TE-400C, TE-410A, TE-412C, TE-420A and TE-4200) which are routed on adjacent fire area / zones 1-P8-42-16 and 1-YD-20-4A.
2. Cables for control room steam generator level instruments LT-3400 A, B ,

and C are routed in this fire area. Cables for redundant steam generator level instruments LT-2400 A, B and C are routed in adjacent fire area / zones 1-PB-42-16 and 1-YD-20-4A.

3. Cables for pressurizer pressure instrument PT-425 are routed in this fire
area. Alternative indication of pressurizer pressure (PT-434A) is
available at the dedicated shutdown panel. Cables for the dedicated i shutdown panel instruments are not routed in adjacent fire areas and are j considered to be independent of the fire area.

! 4. Pressurizer pressure transmitters PT-430 and PT-431 in the subject fire

area could cause spurious operation of pressurizer heater groups A and B ,

! and pressurizer PORV, CV-546. To prevent these spurious actions,

, pressurizer heater groups A and B and PORV, CV-546, or block valve CV-530

'- can be tripped from the control room and left in the trip position. The

circuits for redundant pressurizer heater group C and PORV block valve, CV-530, routed in adjacent fire zone 1-YD-20-4A are located approximately 20 feet below the power block roof elevation. The redundant pressurizer heater group D circuits are located in fire zone 1-YD-20-48, which is 4 separated from the power block roof by greater than 40 feet without
intervening combustibles (at the interface of fire zones 1-YD-20-4A and i 1-YD-20-48).

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FIRE AREA EVALUATION 1-PB-56-33

5. The reinforced concrete roof slab separating this fire area from the control room 1-PB-42-16 presents a substantial barrier to prevent the spread of fire.
6. The nearest in situ combustibles in adjacent fire zone 1-YD-20-4A are located approximately 20 feet below the roof of the power block. Due to the low combustible loading in this fire area (1-PB-56-33) and the spatial separation of the combustibles, a fire is not likely to propogate to the adjacent area.
7. Fire area 1-PB-42-30, with which this area communicates via a ventilation penetration, contains no safe shutdown equipment which is redundant to that on the power block roof.
8. Combustible gases and heat generated by a fire in the area would be dissipated to the atmosphere.
9. Circuits for diesel generator 2 are routed in this fire area. Redundant diesel generator 1 circuits are routed in adjacent fire areas / zones 1 -PB-20-13A,1 -PB-20-12,1 -PB-20-ll A and 1-PB-42-16. Intervening walls and ceilings of these fire areas / zones acts as barriers to preclude the spread of fire from 1-PB-56-33.
10. In addition to the safe shutdown circuits located in the fire areas / zones discussed above, the following operator actions may be required at emergency control stations outside this fire area:

Fire damage to cables for the AFW turbine steam supply valve, CV-3201, and the steam driven AFW pump service water supply valve, SV-3205, could cause spurious operation of these valves and the loss of use of the steam driven AFW pump, G-10. A control circuit for the redundant motor d. tven AFW pump, G-105, is routed in conduit and located in adjacent fire zone 1-TB-35-98. This fire zone is located below the pow 2r block roof. Operator action to deenergize and manually open MOV-1202 and start pump G-105 at the 480VAC switchgear in fire zone area 1-PB-14-8 can be credited if the circuit in 1-TB-35-9B is lost.

Circuits associated with the AFW flow control valves are routed in this fire area. Operator action will be taken to locally control the auxiliary feedwater flow control velves, FCV-2300, 2301, 3300 and 3301, which are located in the yard area (1-YD-14-40) located over 100 feet away from the power block roof.

Circuits associated with the reactor head vent and pressurizer vent valves are routed in this fire area. Operator action will be taken to close reactor vessel vent valve SV-3402 and pressurizer high point vent valve SV-3404 at disconnect switches installed at the penetration zones,1-YD-20-4A and 1-YD-20-4B.

The time required to perform the manual actions has been evaluated to assure adequate time and manpower will be available.

3680h:6837F:8526u Revision 1

o FIRE AREA EVALUATION 1-PB-56-33

11. The San Onofre Fire Department consists of professionally trained full time personnel whose primary responsibility is fighting fires at San Ono fre. The Fire Department is certified by the State of California Fire Marshall's office to provide fire suppression activities. A minimum of five certified fire fighters are on duty per shift. The first arriving fire fighters under normal circumstances can be expected to be on scene within five minutes of the receipt of the alarm.

CONCLUSION:

Based on the above described configuration of the fire area, the low fire loading, and the available path for dissipation of the heat and products of combustion resulting from the fire to the atmosphere, one train of redundant equipment necessary to achieve and maintain hot standby and cold shutdown from the control room and the emergency control stations will remain free of fire damage, and the equipment used to provide alternate shutdown capability is independent of the fire area. This evaluation demonstrates that fire area 1-PB-56-33 is in compliance with the requirements of 10 CFR 50 Appendix R, Section III.G.1, and with 10 CFR 50 Section III.G.3 with consideration given to the pending exemption.

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i 3680h:6837F:8526u Revision 1

FIRE AREA EVALUATION 1-AB-11-34 TITLE: Pipe Tunnel FIGURE: 3-3 ,

INTRODUCTION This evaluation is provided to demonstrate compliance with 10CFR50, Appendix R, Section III.G.1 by demonstrating that for a fire in fire area 1-AB-11-34, the Pipe Tunnel, the redundant cables and components outside this area will remain free of fire damage. Fire area 1-AB-ll-34 contains cables associated with MOV-11000, the VCT isolation valve, and MOV-11008 and MOV-11000, charging pump RWST suction -isolation valves. Cabling for the redundant and associated equipment is located in adjacent fire tones 1-AB-(-3)-2A and 1-YD-14-4D. Fire area 1-AB-11-34 also contains circuits for charging pump G-8A, its auxiliary lube oil pump G-942, and its auxiliary cooling fan MG-8AF. Adjacent fire area 1-AB-14-35 contains circuits for the redundant components, charging pump G-8B, its auxiliary lube oil pump G-943, and its auxiliary cooling fan MG-8BF.

AREA DESCRIPTION Physical Characteristics Fire area 1-AB-ll-34 is located below grade, east of the reactor auxiliary building. The walls are all 3-hour rated. The ceiling is reinforced concrete with an approximate thickness of 9".

This area contains the following unrated openings:

1. There is a concrete plug over a manhole at the north end of the pipe tunnel and a manhole at the south end of this zone communicating with fire zone (1-YD-14-4D).

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2. The northeast end of the pipe tunnel is exposed to zone 1-YD-14-4D
j. through an open grating.

Combustibles l

The in-situ combustible loading in this fire area consists of cable trays I running throughout the area. The fire loading is 11,928 BTU /sq.ft., with an

! equivalent fire severity of 9 minutes.

Due to this area's remote location and confined nature, no significant quantities of transient combustibles are expected to be found.

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FIRE PROTECTION CAPABII.'ITY j Detection -

Ionization smoke detectors are installed in the tunnel.

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3688h:6832F:8523u _ ", Revision 1 n_

r y

FIRE AREA EVALUATION 1-AB-11-34 Suppression There is a portable extinguisher located near each end of this area below the ,

manholes. Manual hose reels are provided in adjacent fire zones with access to the pipe tunnel.

EVALUATION An evaluation is performed to show that the criteria of 10CFR50 Appendix R, Section III.G.1 are met. This evaluation demonstrates that the fire area boundaries will contain a postulated fire and that the redundant train of required safe shutdown equipment will remain free of fire damage. The technical bases which justify the adequacy of the existing separation are listed below:

1. The metal manhole at the south end of the tunnel is approximately one inch thick. Since the fire duration is 9 minutes, the manhole is adequate to contain the fire within the area.
2. The 29" thick concrete plug at the north end of the tunnel is adequate to contain the fire within the area.
3. The fire will not propagate through the opening at the northeast end of the pipe tunnel due to the minimal combustibles in this portion of the pipe tunnel and in the immediate vicinity of adjacent fire zone 1-YD-14-40.
4. Cables for charging pump G-8A, its auxiliary lube oil pump G-942, and auxiliary cooling-fan MG-8AF are routed in this fire area. The redundant components; charging pump G-8B, auxiliary lube oil pump G-943, and auxiliary cooling fan MG-8BF have cables in adjacent areas / zones 1 -YD-14-4D and 1-AB-14-35. In fire zone 1-YD-14-4D, the circuit for charging pump G-8B is provided with a 1-hour rated barrier while the circuits for G-943 and MG-8BF utilize 1-hour rated Rockbestos cable routed in conduit. In fire area 1-AB-14-35 the redundant cables are separated by a 3-hour rated barrier. Auxiliary lube oil pump G-943 has cables in both 1-AB-ll-34 and 1-AB-14-35, but is an auxiliary unit and not required for the operation of charging pump G-88.
5. The VCT isolation valve M0V-1100C and circuits for the RWST supply valves M0V-ll00D and MOV-11008 to the charging pump suction header are located in this fire area. Damage to cables for volume control tank isolation valve MOV-1100C and RWST isolation valves MOV-1100B and MOV-1100D could cause MOV-1100C to remain open, and prevent remote operation of MOV-1100B or MOV-1100D. Damage to these circuits in combination with a loss of letdown could prevent charging pump suction from the RWST. A bypass around MOV-1100B and MOV-1100D utilizing FCV-5051 whose circuits are located in 1-AB-(-3)-2A will preclude a loss of charging pump suction should MOV-1100C spuriously close. If MOV-1100C spuriously remains open, 3688h:6832F:8523u Revision 1 L- j

. . . j FIRE AREA EVALUATION 1-AB-ll-34 a low-level signal in the VCT from LT-1100 will trip charging pump G-8A.

Cables for LT-1100 are routed along the outside of 1-AB-20-2N from fire area 1-AB-ll-35 through 1-YD-14-40. The cables for LT-1100 are provided with a 1-hour protective wrap where they are routed in fire zone 1 - YD-14-4 D .

6. In addition to the safe shutdown circuits located in the fire areas / zones discussed above, the following operator actions may be required at emergency control stations outside this fire area:

Damage to cables for charging flow control valve FCV-lll2 could cause this valve to spuriously open. Operator action to close manual valves VCC-307, 308, 337 and 338 located upstream in fire zone 1-AB-(-3)-2A will be necessary if charging through the seal injection flow path. For higher make up flow rates through charging loop A, FCV-lll2 control will be captured at panel C-38 in fire zone 1-YD-20-4G and the valve regulated to the desired flowrate.

Damage to cables for RCP seal water supply valves FCV-ll15A, B and C could cause these valves to spuriously operate. Operator action is required to fail open these valves and verify closed FCV-1115 D, E and F in the doghouse 1-YD-14-4C.

Damage to cables for primary plant makeup water control valve FCV-1102A could cause the valve to spuriously open, allowing primary plant makeup water to be supplied directly to the charging pump suction. Operator action will be required to close manual valve BAS-344 in fire zone 1-AB-(-3)-2A located downstream of FCV-Il02A to isolate this line. Spurious actuation of the valve, until operator action is taken to close the downstream manual valve, has been analyzed, and determined to be acceptable.

Damage to cables for boric acid supply valves FCV-1102B and CV-334, could cause these valve to spuriously open, allowing concentrated boric acid to be supplied to the charging pump suction. Operator action will be required to close manual valves BAS-344 and BAS-316 respectively to isolate these lines. Spurious actuation of these valves will not affect safe shutdown capability. These valves are located in fire zone 1-AB-(-3)-?A, which is separated from the pipe tunnel by a 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> rated wall.

Damage to cables for the test pump, G-42, could cause spurious operation of the pump. Operator action would be required to deenergize this pump at MCC-2A in fire zone 1-AB-(-3)-2A. Its operation is not required to achieve or maintain hot standby or cold shutdown conditions.

3688h:6832F:8523u Revision 1 L

...J FIRE AREA EVALUATION 1-AB-11-34 Damage to cables for the CCW to RHR heat exchanger flow control valves TCV-601 A and TCV-601B in 1-YD-14-4D could cause these valve to fail open, as required, for safe shutdown. If required, flow control may be achieved using manual valves located downstream, CCW-459 and CCW-461, located in 1-YD-14-4D. These valves are located above the northeast end of the pipe tunnel where the pipe tunnel opens to 1-YD-14-4D. The lack of combustibles at this end of the pipe tunnel in both zones would preclude a fire in the pipe tunnel from gaining access to these valves.

The time required to perform the manual actions has been evaluated to assure adequate time and manpower will be available.

7. The San Onofre Fire Department consists of professionally trained, full-time personnel whose primary responsibility is fighting fires at San Ono fre. The Fire Department is certified by the State of California Fire Marshall's office to provide fire suppression activities. A minimum of five certified fire fighters are on duty per shift. The first arriving fire fighters under normal circumstances can be expected on scene within five minutes of the receipt of an alarm.

CONCLUSION Based on the above described configuration of the fire area and the detection capability provided, this evaluation demonstrates that one train of systems necessary to achieve and maintain hot standby and cold shutdown conditions from the control room and emergency control stations will remain free of fire damage. This evaluation demonstrates that fire area 1-AB-14-35 meets the requirements of, and is in compliance witn 10 CFR 50 Appendix R, Section III.G.I.

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-4 3688h:6832F:8523u Revision 1

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