ML20210D527

Provides Confirmation of 870116 Prompt Notification to NRC & 14-day Written Followup Rept Per License Condition 2.G.Addl Listed Items Determined Reportable During Addl 10CFR50,App R Analyses Initiated Per Guidance in Generic Ltr 86-10

ML20210D527
Person / Time
Site:	San Onofre
Issue date:	01/19/1987
From:	Morgan H SOUTHERN CALIFORNIA EDISON CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
GL-86-10, TAC-54218, TAC-54814, TAC-54815, NUDOCS 8702100108
Download: ML20210D527 (4)

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Southem Califomia Edison Company & Q *G SAN ONOFRE NUCLEAR GENERATING STAT 60N y PO BOK128 s' Q

SAN CLEMENTE, CALIFORNIA 92672 ,3 H.E MORGAN T m PHONE staron ua=*oca ~"

January 19, 1987 U. S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596-5368 Atten tion: Mr. J. B. Martin, Regional Administrator

Subject:

Docket Nos. 50-361 and 50-352 Prompt Report License Condition 2.C. (14)a and 2.C. (12)a San Onofre Nuclear Generating Station, Units 2 and 3 This submittal provides written confirmation of our prompt notification to the NRC on January 16, 1987 and the 14 day written follow-up report pursuant to License Condition 2.G of Facility Operating Licenses NPF-10 and NPF-15 for San Onofre Units 2 and 3, respectively.

License Condition 2.C. (14)a and 2.C. (12)a of Operating License NPF-10 and NPF-15, respectively, require that SCE maintain in effect and fully implement the Fire Protection Plan as delineated in the Fire Hazards Analysis (FHA). Additionally, San Onofre Units 2 and 3 have committed to meet the technical requirements of Sections III.G, III.J and III.0 of Appendix R to 10 CFR 50. Only those deviations from the Fire Protection Plan that violate tha requirements of Sections III.G, III.J and III.0 of Appendix R to 10 CFR 50 ar.d are not otherwise subject to Technical Specification Limiting Conditions for Operation are required to be reported in accordance with License Condition 2.G.

In March 1984, SCE transmitted the San Onofre Units 2 and 3 Updated Fire Hazards Analysis (UFHA) to the NRC along with eight (8) deviations to 10 CFR 50, Appendix R. At the time the UFHA was submitted, the NRC focused its fire protection reviews on near-term operating license plants. Since San Onofre Units 2 and 3 had already received operating licenses, NRC review of the UFHA and the eight deviation requests was delayed and has not been completed as of this time.

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e MR. J. B. H ARTIN Subsequent to SCE's submittal of the UFFA, the NRC issued new guidance for meeting the technical requirements of Appendix R (e.g., Draft Generic Letter 85-01, issued formally as Generic Letter 86-10). By letter dated September 19, 1985, SCE informed the NRC that additional Appendix R analyses were being initiated in light of the latest NRC guidance.

In May 1986, SCE was informed by the NRC's Office of Nuclear Reactor Regulation (NRR) that the San Onofre Units 2 and 3 fire protection docket was being reviewed and that this was being conducted as a "first time" review. A follow-on conversation was held with the NRR reviewer in Septenber 1986 at which time NRR indicated that review of the docket had been completed. Based on NRR's review, a number of items required clarification by SCE prior to NRR issuing a revised Safety Evaluation Report (SER) which would document final resolution of SCE's outstanding Appendix R/ fire protection issues in regard to Standard Review Plan Section 9.5.1.

The items requiring further clarification were documented in a formal NRC Request for Additional Information (RAI) dated October 6,1986.

The NRC RAI and other fire protection issues have been the subject of recent discussions between SCE and NRR. In one discussion, SCE reinformed NRR of the ongoing Appendix R analyses and agreed to provide a submittal documenting the safe shutdown analyses. NRR noted favorably that SCE uas reassessing Appendix R compliance in light of the new guidance issued. It was agreed that any Appendix R deviations, or potential areas of concern resulting from the reanalysis should be brought to the NRR reviewer's attention prior to issuance of the revised SER. Both NRR and SCE expect that additional conversations and meetings will be necessary prior to final resolution of the outstanding Appendix R/ fire protection issues and issuance of the revised SER.

SCE is in the process of finalizing the additional Appendix R analyses.

Although the analyses are not fully complete, the following items have been determined to be reportable under the provisions of License Condition 2.G.

1. The independence of circuits associated with the alternate shutdown capability established in accordance with 10 CFR 50, Appendix R, Section -III.G.3 were determined to be deficient in each of the following three areas:

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MR. J. B. M ARTIN a) Unit 2 HVAC Room 2B - Although this room is equipped with fire detector and water suppression equipment, cabling for that portion of the Emergency Chilled Water System providing cooling to the Essential Plant Parameter Monitor (EPPM) panel power supply was not protected against fire damage in accordance with 10 CFR 50, Appendix R, Section III.G.2.

Since the EPPM is relied upon for alternate shutdown capability, the requirements of Section III.G.3 are considered to have not been met.

b) Unit 2 Cable Spreading Room - Although this room is equipped with fire detectors and water suppression equipment, cabling providing Steam Generator Pressure indication to the EPPM was not protected against fire damage in accordance with 10 CFR

! 50, Appendix R,Section III.G.2. Since this paraneter would be relied upon to achieve safe shutdown using the alternate shutdown capability, the requirements of Section III.G.3 of Appendix R, regarding independence of such circuitry, is considered to have not been met.

c) Unit 3 Cable Riser Gallery - Cables providing power to the EPPM are not routed independent of cable relied upon for nornal shutdown equipment. Sinca the EPPM is relied upon for alternate shutdown capability, the requirements of Section III.G.3 are considered to have not been met.

2. Although not required to be protected against fire damage in accordance with Appendix R, SCE had committed in the Fire Hazards Analysis (FHA) that the provisions of Appendix R would be applied to Spent Fuel Pool Cooling equipment as if it were required for safe shutdown. Cabling for redundant trains of Spent Fuel Pool Cooling Pumps and supporting HVAC units were found to not be separated or protected against fire damage as required by Appendix R Section III.G.2 and the condition therefore did not meet the FHA commitnent.

These reportable items have been documented through the Nonconfornance Report (NCR) process and appropriate compensatory measures have been established.

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MR. J. B. MARTIN As with any reanalysis, the potential exists for identification of additional fire protection discrepancies. SCE will submit a follow-up report to EC Region V, within 30 days, which will provide additional detail on the four items identified as well as any other reportable issues which result from the analyses. In addition, SCE will continue its current efforts with NRR to expeditiously resolve outstanding San Onofre Units 2 and 3 Appendix R/ fire protection issues.

If you require additional information, please so advise.

Sincerely,

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cc: l' S. Nuclear Regulatory Commission, Document Control Desk F. R. Huey, (USNRC Senior Resident Inspector, Units 1, 2 and 3)

H. Rood, (USMC Project Manager) l

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