ML20136H112
| ML20136H112 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/31/1982 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20136D968 | List: |
| References | |
| FOIA-85-425 NUDOCS 8508200162 | |
| Download: ML20136H112 (11) | |
Text
. -. - . _ _ _ . _ . _ w i i Chemical Engineering Branch / Fire Protection Section .
t Supplemental Safety Evaluation Report '
Fire Protection San Onofre Nuclear Generating Station Units 2 and 3 Docket Nos. 50-361/362 _ .
In the SER we stated that based on the applicants' commitments to modify the facility, we believed that the San Onofre 2 and 3 fir.e protection program will meet the requirements of -
Appendix R to 10 CFR 50 when the committed modifications had been completed. However, since Appendix R did not apply to_ San Onofre 2 and 3 at the time our fire protection review was conducted, we did not require the applicants to specifically evaluate all aspects of the fire protection program for compliance with Appendix R.
Since that time, our fire protection criteria have been delineated in NUREG-0800 (the Standard Review Plan), Section 9.5.1, which also includes Appendix R. We therefore conditioned the San Onofre 2 operating license to require the applicants to submit the evaluation of the plant against the criteria of Section 9.5.1 of NUREG-0800 prior to exceeding 5 percent power. In the interim, plant operation was considered acceptable because of the reduced risk associated with operation at low power, and because the staff's audit review described -
in the SER indicated compliance with Appendix R or an equivalent level of protection. By letter dated July 22, 1982 the applicants provided a comparison of the plant fire protection program against the criteria of Section 9.5-1 of NUREG-0800. In addition, the .,
letter identified inconsistencies in the SER. By letter dated .
July 27, 1982 the applicants committed to meet the technical requirements of Section III.G " Fire Protection of Safe Shutdwn Capability," III.J " Emergency Lighting", and III.0 " Oil Collection System for Reactor Coolant Pump" of Appendix R to 10 CFR 50 and proposed plant modifications to comply with our guidelines. Our evaluation of each of the requested deviations, and proposed modification is as follows:
8501N200162 850722 PDft FOIA BELL 85-425 PDR
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2 A. BTP CMEB 9.5-1 Item C.3.b Item C.3.b recommends that the Fire Brigade leader and at least two . .
Brigade members should have sufficient knowledge of plant safety related systems to assess the effects of fire and fire suppressants on safe shutdown capability as evidenced by possession of an Operator's license or equivalent knowledge. The applicants currently have a full '
time Fire Brigade consisting of five members on each shift, whose sole function is fire protection. The brigade membere-have.had training in plant systems in order to develop basic skills with which to assess the effects of fire on safe shutdown capability, however they do not have the equivalent knowledge of an operator.
To compensate each shift will also have an Assistant Control Operator to serve as the sixth member of the Fire Brigade, and assess the effects of the fire and fire suppressants on safe shutdown capability and communicate the same to the Watch Engineer l- in the Control Room.
We agree that the applicants addition of the Assistant Control Operator to the fire brigade will provide an acceptable level of - - -
plant systems knowledge within the fire brigade. The qualification of the fire brigade members are equivalent to the guidelines of Section C.3.5 of BTP CMEB 9.5-1. Therefore, we find the applicants' request for a deviation acceptable . .- -
BTP CMEB 9.5-1 Item C.5.a(5)
Item C.5.a(5) recommends that areas protected by total flooding gas suppression systems have electrically supervised self-closing fire doors. Unit 2 and Unit 3 Computer, Rooms located on the 30' l
elevation of the Auxiliary Building are protected by total flooding '
Halon systems. Doors to the computer rooms are not electrically
" supervised. The computer rooms are located in close proximity to j the main control room which is continuously manned. If the computer ,
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room doors were left open, an operator would notice and promptly take action to ensure their proper closure. Based on the above we conclude that the door supervision provided for the computer rooms . .
is equivalent to that required by Section C.5.a of BTP CMEB 9.5-1.
Therefore, we find the applicants' request for a deviation acceptable.
BTP CMEB 9.5-1 Item C.6.a(1)
Item C.6.a(1) recommends that fire detection systems be provided for all areas that contain or present a fire exposure to safety related equipment. In our SER, we stated that the applicants had committed to provide fire detection systems in all safety related areas. The i
applicants have now proposed that 23 fire areas within the plant not have fire detection systems. The basis for their deviation is that the. fire area has a low fire load, the equipment in the fire area consists of tanks or piping only, and/or the area was previously reviewed by us and, subsequently, approved.
We accept a deviation from this requirement for the following '- -
areas because there are essentially no combustibles in the area:
Fire Zone Name 8 Waste Gas Decay Tanks
- 14 Boric Acid Make-Up Tank Rooms )
18 Diesel Fuel Oil Storage Tank l
20 Condensate Storage Tank Room 21 Nuclear Service Water Storage Tank 23 Spent Fuel Pool Heat Exchange Room 37 Letdown Heat Exchanger Rooms 38 Letdown Control Valve Rooms 48 CCW Heat Exchanger Rooms 51 Boric Acid Make-Up Pump Rooms .
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54 Shutdown Heat Exchanger Rooms 56 Component Cooling Water Surge Tank Rooms l 69 Salt Water Cooling Piping Rooms . .
70 Duct Shaft 75 Refueling Water Storage Tank 80 Duct Shaft 81 -
, Duct Shaft '
82 Auxiliary Feedwater Pipe Tunnel We do not accept a deviation from the fire detection requirement for the following fire areas because of the fire loading in these areas:
Fire Zone Name 11 Main Steam Relief Valve Rooms 62 Volume Control Tank Rooms 72 Corridor 401, Control Bldg. Elevation 70' l By letter dated July 27, 1982 the applicants committed to provide
- fire detection in fire zones 11, 62, 72. With this commitment, we - -
find the fire detection provided for safety-related areas meets the guidelines of Section C.6.a. Therefore, we find the applicants' request for a deviation acceptable.
BTP CMEB 9.5-I Item C.7.f -
Item C.7.f recommends that redundant safety related panels remote -
from the control room be separated from each other by a minimum of three-hour fire rated barriers. Additionally, panels providing t
remote shutdown capability should be separated from the control room complex by a minimum of three-hour fire rated barriers. The .
applicants have provided alternate safe shutdown capability independent of the control room and cable spreading room. Fire zone 66 contains the train A and train 8 remote shutdown panels. .
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5 The train A and B remote shutdown panels are not separated from each cther by a three hour fire rated barrier. The remote shutdown panels are electrically isolated from the control room and are separated by a two- .
hour rated fire barrier, previously found acceptable because of the low fuel load. In the event of a fire in either the control room or the remote shutdown panel, the two areas are electrically and physically separated,'therefore a fire in one area will not affect the other areas, the plant will be safely shutdown from the unaffected area. Based on the above evaluation, we conclude that the separatfortf the remote shutdown panel is equivalent to the guideline of Section_C.7.f. There-fore, we find the applicants' request.for this deviation acceptable.
BTP 9.5-1 Item C.7.i Item C.7.1 recommends that automatic fire suppression systems inscalled to combat diesel generator fires, be designed for operation when the diesel generator is running without affecting the diesel. The applicants' diesel generators are not designed and have not been tested to operate ,
while being sprayed by the sprinkler system. The arrangement of the diesel generators is such that if spray deflectors are ' installed', they ' -
would render the extinguishing system ineffective. In addition, redundant trains of diesel generators protected by separate
- sprinkler systems are provided. In the event one train is rendered inoperative due to a fire or inadvertant operation of the sprinkler-system, the -
redundant train would be unaffected. Based on the above evaluation'we find that one train of diesel generator needed for safe shutdown will be maintained free of fire damage and therefore equivalent protection 'is provided to Section C.7.i of BTP CMEB 9.51. Therefore, we find the l
applicants' request for this deviation acceptable.
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BTP CMEB 9.51 Item C.7.k -
Item C.7.k recommends that redundant trains of safety related pumps be separated by three hour fire rated barriers. Originally there was one .
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6 mechanical driven and one steam driven auxiliary feedwater pump in the auxiliary feedwater room. The room is provided with a sprinkler system.
The two pumps were not separated by one-hour rated fire barrier as our_ .
guidelines recommended. Instead, we accepted a) enclosure of the cable to the motor driven pump in a one-hour rated wrap; b) the installation of a drain to remove any possible oil leakage from the steam driven pumps; and c) the existing missile shield as a partial barrier between the two '
pumps, as an equivalent level of protection. Since our SER was issued, a third AFW pump has been installed in the pump room,-ench no additional fire protection measures have been provided. By letter dated July 27, 1982, the applicants stated that additional fire protection measures were unecessary and could be detrimental to pump maintenance, however the applicants at our request have committed by letter dated July 29, 1982 to install a portable sheet metal barrier between the new AFW pump and the existing steam driven AFW pump. With this commitment, we find that a level of safety equivalent to the guidelines of Section C.7.k will be provided. Therefore, we find the applicant's request for a deviation in this area acceptable .
BTp CMEB 9.5-1 Item C.6.b(6) - - - -
1 Item C.6.b(6) recommends that each fire pump and its driver and controls be separated from the remaining fire pumps by three hour fire rated barriers. The fire pumps are not separated by three -
hour fire rated barriers. In the event that the fire pumps are -
disabled by a fire, fire fighting water would still be available by using the plant fire truck and/or the interconnection between the Unit 1 and Units 2 and 3 fire mains. Based on the above evaluation, we accept this deviation as providing an equivalent level of safety as that recommended by the guidelines in Section C.6.b, therefore the applicants' request for a deviation in this area is acceptable.
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7 BTP CMEB 9.5-1 Item C 7.a(1)(e)
Item C.7.a(1)(e)' recommends that the reactor coolant pumps be . -
equipped with an oil collection system which is designed, engineered and installed such that its failure will not lead to fire during normal or design basis accident conditions and that there"is a reasonable assurance that it will withstand a .
safe shutdown earthquake. The applicants' interpretation of this guideline is correct. An acceptable oil collechten system has been provided, therefore a request for a deviation is not needed.
B. SER Statements Which are Inconsistent With Information Provided by the applicants:
By letter dated July 22, 1982, the applicants brought to our attention the following comments we made in the SER.
- 1. On page 9-20 of the SER, we stated that "All valves in the fire protection water supply system are electrically supervised
'except for the post indicator valves, which are in the under-ground yard main system." The applicants have stated'that the' - -
Header isolation valves for seismic standpipes and locked open manual isolation valves to deluge systems are not electrically supervised.
We find that this method of controlling valve position is.in -
accordance with NFPA Std. 26, " Supervision of Valves." It provides a level of protection equivalent to Section C.6.c
- of BTP CMEB 9.5-1, and is, therefore, acceptable.
- 2. On pages 9-20 and 9-21 of the SER, we stated that;
- 1) "The areas that have been equipped with water suppression systems include the following:"
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- Fan Rooms 219 and 221, Charcoal Filter -
Zone 32A .
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- Emergency A.C. Unit Room 308, Charcoal Filters - Zone 9
- Emergency A.C. Unit Room 301, Charcoal . .
Filters - Zone 9
- Piping Penetration Area (El 30') Charcoal
, Filter - Zone 28 i . .
- 2) " Corridor 492, Elevation 70' Auxiliary Building - Zone 72*"
l 3) "* Sprinkler system installed at our request." Control Room Complex - Zone 31*
- Turbine Lab
- Instrument Repair Area
- Storage, Rooms 249, 251, 252 The applicants have stated that: 1) manual water suppression systems are provided for the charcoal filters only. No area 4
1 sprinklers are provided in these zones. 2) Corridor 401 was incorrectly identified as corridor 442, and 3) The use of these areas has changed with the addition of the Technical Support - ~
Center TSC). We find that: 1) the manual sprinkler system for the l
charcoal filters provides a level of safety equivalent to the guidelines in Section C.6.c of BTP CMEB 9.5-1 and is, therefore
- acceptable. 2) the change in identification of corridor _442 as -
corridor 401 is a typographical error and we will correct it, '
and 3) by letter dated July 27, 1982 the applicants committed to provide fire detection and portable water-type extinguisher in the Technical Support Center complex in lieu of automatic sprinklers.
Based on the low combustible loading in this area, we find the proposed fire protection acceptable. ,
- 3. On page 9-21 of the SER we stated:
"At our request, the applicants have installed standpipe hose .
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- stations in five zones 4, 10, 28 and 45." The applicants have not installed standpipe hose stations in zones 28 and 45. By letter dated July 27, 1982 the applicants committed to install fire . -
detection in these two fire zones. Based on the low fire load in these areas and the availability of extra lengths of fire hose on i
the plant fire truck, we conclude that a level of safety equivalent to that recommended is our guidelines in Section C.6.c will be provided, and is, therefore acceptable.
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- 4. On page 9-24 of the SER we stated :
, "However, the ventilation ducts which penetrate the heavy concrete walls enclosing the charging pump r'oom (Zone 50) were not provided with dampers. At our request, the applicants have committed to provide 1- hour dampers for these duct penetrations."
The applicants stated that this commitment was in error. By letter dated July 27, 1982 the applicants committed to provide a 1 -hour fire damper for one of the three charging pump rooms.
The charging pumps are separated from each'other by 3-hour' rated'~ ~ ~
barriers. Only one charging pump is needed for safe shutdown.
Each room has an independent HVAC duct to the corridor. The applicant has not provided dampers in these HVAC ducts. There is no communications between the three charging pump rooms. ~-
Therefore, the common fire that could affect the performance of all charging pumps would be a fire in the corridor. The most likely combustible in the corridor would be lube oil needed for these pumps. A fire damper in the HVAC duct will effectively isolate the charging pump room. Since only one charging pump is needed for safe shutdown, the isolation of only one charging pump room is necessary. Because the applicant has agreed to provide this fire damper, we find that this provides a level of safety equivalent to our guidelines in Section C.S.a of BTP CMEB 9.5-1, and is, therefore, acceptable. .
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10 C. Sumary of Deviations The applicants' requests for deviations in the following areas . .
which include those previously approved in the SER are acceptable:
- 1. The fire brigade leader's qualifications will not be as recomniended by Section C.3.b, however a sixth member will be added to the fire brigade who will be an assistant operator.
- 2. The doors to the computer rooms on the 30' elevation will not be electrically supervised as recomended by Section C.5.a. Instead this area is continuously manned 5 by the control room operators.
- 3. Fire detectors will not be installed in 19 areas identified in the applicants' July 27, 1982 letter containing safety related equipment, as recomended by Section C.6.a.
These areas do not contain combustible materials.
- 4. The remote shutdown panels will not be separated by 3-hour ' ~ ~
rated fire barrier as recommended by Section C.7.f. Instead they will be electrically isolated from the control room and separated by a 2-hour barrier.
The fire extinguishing system for the diesel generators is
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not designed for operation without affectng the diesel as recomended by Section C.7.1. Redundant diesel generators are provided, protected by separate extinguishing systems.
- 6. The auxiliary feedwater pumps are not separated by 3-hour rated barriers, however a portable shield is providt.d between the steam driven pump and the newly installed
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mechanical driven pump, and a one-hour barrier and sprinkler system is provided between the steam driven .
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pump and existing mechanical driven pump.
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- 7. The fire pumps are not separated by 3-hour rated fire barriers as recommended by Section C.6.b. Instead a cross tie is provided between units. . -
- 8. The oil collection system for the reactor coolant pumps is in accordance with our guidelines. A request for a deviation is not needed.
- 9. Hose standpipes will not be installed in fire zones and 45asrecommendedbySe,ctijnC.6.c,instead,firedetectors i will be provided.
l 10. Only one of the three charging pump rooms will be provided with a fire damper instead of the recommended guidelines in Section C.S.a. Only one pump is needed for safe shutdown.
- 11. An adequate number of sectionalizing valves have not been provided for the fire main recommended by Section C.6.b.
Instead, a backup system is provided.
- 12. Three-hour fire rated barriers are not provided in all areas of the plant as recommended by Section C.S.a. Fire barriers of lesser fire resistance are accepted in various plant areas listed in paragraph 9.5.1.3 of our SER (NUREG-0712... Feb. 1981) -
based on the fuel load in the area. * *
- 13. Approved fire door assemblies are not provded in fire zones 44, 83 and 50 as recommended by Section C.S.a. Alternative doors are provided which provide adequate fire resistance.
- 14. Not all redundant trains are separated by 3-hour rated fire barriers as recommended by Section C.S.b. One-hour rated fire barriers in conjunction with automatic suppression systems have been accepted for those plant areas listed in paragraph ,
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9.5.1.6 of our SER (NUREG-0712, Feb.1982), based on the fuel load in the area.
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Southern California Edison Company .
P. O sox 800 2 2 44 W ALNUT GROVE AVENU E ROSEMEAD CALIFORNI A 31770
) K. P. 5 AS KIN ' t L E *" O
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' ."c C.'.". .' " ' October 28, 1982 Director, Of fice of Nuclear Reactor Regulation Attention: Mr. George W. Knighton, Branch Chief Licensing Branch No. 3 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:
Subject:
Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station Units 2 and 3 License Condition 2.C(14)c of tne San Onofre Nuclear Generating Station Unit 2 (SONGS 2) Operating License, NPF-10, required that Southern Cclifornia Edison Company (SCE) identify and describe any deviations of the SONGS 2 fire protection system from the acceptance criteria of Section 9.5-1 of tne Standard Review Plan (NUREG-0800, dated July 1981). On July 22, 1982 SCE submitted a letter to the NRC to satisfy tnis license condition.
Subsequently, it has been brought to SCE's attention that an additional area of SONGS 2 and 3 fire protection is not in literal compliance witn the Branch Technical Position (BTP) 9.5-1 guidelines. Specifically, BTP 9.5-1, item C.5.a(3) recommends that, for conduit penetrations through fire barriers, openings inside conduit 4 inches or less in diameter should be sealed at the fire barrier unless the conduit extends at least 5 feet on each side of the fire barrier and is sealed at both ends or at the fire barrier with noncombustible material to prevent the passage of smoke and hot gas.
This is a new requirement over previous guidelines wnich were not specific as to the configuration of the conduit seals and only required that the seal fire rating be at least equivalent to that of the penetrated fire barrier. Tne purpose for internal sealing of conduit is to restrict the passage of smoke ;
and hot gases, thus preventing fire from propagating through fire barriers and af fecting redundant trains of safety related equipment. While the l configuration of internal conduit seals at SONGS 2 and 3 differs from that recommended in BTD 9.5-1, it meets these functional criteria.
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Mr. George W. Knighton October 28, 1982 All conduit used at SONGS 2 and 3 is 4 inches or less in diameter.
Conduits which penetrate fire barriers are internally sealed at or near the fire barrier with noncombustible silicone foam which provides an equivalent fire rating to that of the penetrated barrier and restricts the passage of .
smok e. The noncombustible silicone foam sealing material is the same as that used for fire barrier penetration seals. The penetration seals have been tested to demonstrate that the penetration seal is of equivalent fire rating to that of the penetrated barrier and that it remains intact and does not allow the projection of water beyond the unexposed surface. In addition to internal sealing of conduits, the use of cable with self-extinguishing flame retardent insulation further reduces the probability of fire propagating past fire barriers through conduit. All cable insulation used at SONGS 2 and 3 meets the requirements of IEEE 383-1974 with the exception of the PVC insulation used on a limited number of non-safety related communications cables which are identified in the Fire Hazards Analysis.
Based upon the above, SCE considers that the conduit internal sealing criteria used at SONGS 2 and 3 effectively prevents fire from propagating through conduit and affecting redundant trains of safety related equi pment. Even though the configurations of internal conduit seals at SONGS 2 and 3 differ from those recommended by BTP 9.5-1, SCE believes that acceptable fire protection has been provided.
Snould you have any questions regarding this information, please
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Very truly yours, WB&
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cc: Harry Rood, NRC (to be opened by addressee only)
R. H. Engelken, NRC Region V
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