ML20136E078

Safety Evaluation Supporting Fire Protection Program, Providing Mods Are Made Before Fuel Loading

ML20136E078
Person / Time
Site:	San Onofre
Issue date:	01/19/1981
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20136D968	List: ML20136D963 ML20136D969 ML20136E072 ML20136E078 ML20136E282 ML20136G965 ML20136G994 ML20136H076 ML20136H093 ML20136H112
References
FOIA-85-425 NUDOCS 8103030036
Download: ML20136E078 (18)

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FIRE PROTECTION SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION U.S. NUCLEAR REGULATORY COMMISSION IN THE MATTER OF THE .

SOUTHERN CALIFORNIA EDISON COMPANY SAN ONOFRE NUCLEAR GENERATING STATION UNIT NO. 2 AND 3 DOCKET NO. 50-361/362

' JANUARY 19, 1981 O

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SAN ON0FRE EVALUATION REPORT FIRE PROTECTION REVIEW Table of Contents I. INTRODUCTION ................................................. 1 II. FIRE PROTECTION SYSTEMS DESCRIPTION AND EVALUATION ........... 2 A. Wat er S u pp ly Sys tems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 B. Sprinkler and Standipie Systems........................... 4 C. Gas Fire Suppressions Systems ............................ 7 D. Fire Detection Systems.................................... 7 III. OTHER ITEMS RELATED TO FIRE PROTECTION PROGRAMS............... 8 A. Fire Barriers and Fire Barrier Penetrations .............. 8

3. Fire Doors and Dampers ................................... 8 IV. SEISMICALLY INDUCED FIRES .................................... 9 -

V. Alternate shutdown ........................................... 10 VI. PLANT AREAS CONTAINING REDUNDANT DIVISIONS ................... 11 VII. EMERGENCY LIGHTING ........................................... 12

~ VIII. -FIRE PROTECTION FOR SPECIFIC AREAS ........................... 12 A. Control Room ............................................. 12 B. C ab l e S p re adi n g R oom . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 C. Containment .............................................. 14 D. Other Plant Areas ........................................ 14 IX. ADMINISTRATIVE CONTROLS AND FIRE BRIGADE . . . . . . . . . . . . . . . . . . . . . 14 X. TECHNICAL SPECIFICATIONS ..................................... 15 XI. APPENDIX R STATEMENT .......................................... 15 XII. CONCLUSION ................................................... 16 O

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CHEMICAL ENGINEERfNG BRANCH /F1RE PROTECTION SECT 10N FIRE PROTECTION REVIEW SAN ONOFRE 2 & 3 DOCKET NO. 50-361/362  ;

I. INTRODUCTION We have reviewed the San Onofre 2 and 3 fire protection program reevaluation and fire hazards analysis submitted b'y the applicant by letter dated October 31, 1977, including Revisions 1 through 4. The San Onofre Nuclear Generating Station is a three unit site. San Onofre Unit 1 is operating and we have evaluated the. fire protection program separately. However, we have discussed and evaluated areas that have interactions between the three Units.

The San Onofre 2 and 3 reevaluation was in response to our request to evaluate their fire protection program against the guidelines of Appendix A to Branch Tecnnical Festion (BTP) APCSB 9.5-1, " Guidelines for Fire Protection for Nuclear P:wer Plants.

As part of our review, we visited the plant site to examine the relationship of safety related components, systems, and structures in soecific plant aress to both

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c:mbustible materials and to associated fire detection and suppression system. The overall objective of our review was te ensure that in the event of a fire at San Onofre 2 and 3, personnel and the plant equipment would be adequate to safely shutdewn the reactor, to maintain the plant in a safe shutdown condition, and to minimize the release of radioactivity to the environment.

Our review included an evaluation of the automatic and manually operated water and

• gas fire suppression systems, the fire detection systems, fi re barri ers, fire doors and dampers, fire protection administrative controls, and the fire brigade size and training.

Since Units 2 and 3 are of the same design except as noted, the comments made in this report apply to both Units.

. Our conclusion, given in Section XII is that the Fire Protection Program of San Onofre 2 and 3 with the proposed improvements, is adequate and meets General Design Criterion 3. We consider that the fire, detection and suppression systems, the barriers between fire areas, administrative procedures for control of combustibles e

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and ignition sources, and the trained onsite fire brigade with the capability to extinguish fires manually will provide adequate protection against a fire. ' Our consultants, Gage-Babcock and Associates, Inc. , participated in the review of the fire protection program and in the preparation of this safety evaluation report, and concur with our findings. .

II. FIRE PROTECTION SYSTEMS DESCRIPTION AND EVALUATION A. Water Supply Systems The water supply system is common to both units. It consists of three fire pumps connected through a common header to a 12-inch cast-iron, cement-lined pipe yard main. Two electric motor' driven fir 2 pumps are rated at 1500 gpm at 128 psi head each and the diesel engine driven fire pu=p is rated at 2500 gpm at 125 psi head. The fire pumps and their controllers are !!L Listed. Their design and installation conforms to the requirements of NFpA .20 Standard for the Installation of Centrifugal Fire pumps."

P The pumps take suction from two 375,000 gallon water str<o 3e tanks, of which 300,000 gallons in each tank are reserved for fire pro:=:lica, through a common heacer. The pumps discharge into a common header with twc separate connections to the underground 12-inch yard main loop. The original design of both the

• suction and discharge headers was such that a single break could cause the loss

" of two of the three pumps. At our request, the apolicant modified the suction and discharge headers so that a single break will not incapacitate more then one pump.

Two separate 60 gpm jockey pumps automatically maintain yard main pressure at 135 psi. The fire pumps start automatically on low header pressure. If the water supply system pressure falls to 105 psi, one of the electric fire pumps.

starts automatically. As the p' essure falls to 100 psi and 95 psi, the second electric pump and the diesel engine driven pump st' art, respectively, after short time delays. The pumps can also b,e started manually from the control roem and at the pumps. The pumps can be stcpped only at the pump control"ler panels located adjacent to the pumps. ,5eparate alarms are provided in the control room to monitor pump operation, prime mover availability, and failure of a fire pump to start.

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The largest single fire suppression system water demand for . areas that need to be-piotected is 1860 gpm. This occurs in two areas, namely, one section of the cable spreading room and in cable tunnel section 7. However, the two adjacent deluge systems being a,ctuated simultaneously would raise the' required water flow to 3450 gpm. Adding 500 gpm for hose streams creates a total water demand of 3950 gpm. The two electric motor driven fire pumps operating together, er one electric motor driven pump and the diesel engine driven pump operating together, can deliver the required water flow.

The San Onofre 2 and 3 water supply system is augmented by the Unit 1 system.

The Unit 1 supply system consists of two 1,000 gpm at 120 psi electric motor driven fire pumps, which the suction from a 3 million gallon storage reservoir, with 300,000 gallons reserved for fire protection. The Unit 1 pumps are capable of being supplied .from the emergency diesel. gener.ators at JJnit 1.

A discussicn of the fire protection water requirements following a seismic event is discussed in Section 9.5-1.4 of this report.

All valves in.the fire protection water supply system are electrically -

supervised except for the post indicator valves, which are in the underground yard main system. The post indicator valves are locked open under administrative

, controls. The electrical supervision of valves alarms in the control room. The water supply valves meet the requirement of Appendix A, section C.3.b and are, therefore, acceptable.

We find that the water supply system, with the indicated modification, can deliver the required water demand with one pump out of service. We conclude that the water supply system is adequate., meets the guidelines of section 0.2,of Accendix A, and is, therefore, acceptable.

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8. Sprinkler and Standoipe Systems The wet pipe sprinkler systems, preaction sprinkler deluge systems, and water spray systems, are designed to the requirements of National Fire Protection Association (NFPA) Standard No. 13 " Standard for Installation of Sprinkler Systems," and NFPA 15, " Standard for Water Spray Fixed Systems."

The areas that have been equipped with water suppression systems include the following:

Containment

- Charcoal Filter Area (EL 45)

- Combustible Oil Area ,

Cable Riser Galleries - Zone 5 -

Emergency A.C. Unit Room 308, Charcoal Filters - Zone 9 Emergency A.C. Unit Room 301, Charcoal Filters - Zone 9 Cable Riser Galleries - Zone 12 Emergency HVAC Unit Room 309A - Zone 13A*

ESF Switchgear Rooms 308A and 8 - Zone 15" '

Diesel Generator Buildings - Train A & 8 - Zone 17 Auxiliary Feedwater Pump Room - Zone 22" Spent Fuel Pool Heat Exchangers Room - Zone 23" Low Radioactive Waste Storage Area - Zon'e 24 Piping Penetration Area (EL 30) Charcoal Filter - Zone 28 Cable Riser Galleries - Zone 29 Electrical Tunnel (EL 30'-6") - Zone 30 '

Control Room Complex - Zone 31* -

- Turbine Lab, Room 230

- Instrument Repair Area, Room 248 -

-Storage, Rooms 249, 251, 252 ,

w Sprinkler system installed at our request.

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- Fan Rooms 219 & 221, Charcoal Filter - Zone 32A Fan Rooms 233 & 234 - Zone 328

- Charcoal Filters *

- General Area * -

Spent Fuel Pool Pump Room - Zone 36" Cable Spreading Rooms - Zone 41 Cable Riser Galleries - Zone 42 Intake Structure - Zone 44" CCW Heat Exchangars and Piping Rooms - Zone 48" Electrical Tunnel - Zone 53 (EL 9'-6") .

i Corridor, Elev 50'-0", Auxiliary Building - Zone 63* .

Cable Riser Galleries - Zone 67 Cable Riser Shaft - Zone 63 .

Corridor 442, Elev. 70', Auxiliary Building - Zone 72" General Issue Room 425, Elev. 70'-0", Auxiliary Builcing"

, Corridor Room 105 - Zone 78" Salt Wa'ter Cooling Tunnel, Train A, Train 8 - Zone 83*

Safety Equipment Buialing. Elevation 8' A/C Room No. 017 - Zone 84*

Turbine Building .

- Feedwater Pumps and Turbines .

- Hydrogen Seal Oil Unit

- Hydrogen Gas Control Cubicle

- Lube Oil Room

- Main' Lube Oil Tank Room - Zone 86 -

Manual hose stations are located throughout the plant to ensure that an effective hose stream can be directed to any safety related area in the plant excapt for the cable tunnels (Zones 30 and 53), the new and spent fuel storage areas (Zone 4), the electrical penetration area (Zone 10), and the piping

• penetratic. areas (Zones 28 and 45). At our request, the applicant has

. installed standpipe hose stations in five zones 4,10, 28 and 45. . The applicar.t

" Sprinkler system installed at our request. ,

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has installed.four 75 foot lengths of fire hose at each of two standpipe hose ,

stations near the auxiliary building entrance to fire zone 30 to provide hose stream capability to the cable tunnels. In addition, hose streams from the yard hydrants can be used to suppress fires in the cable tunnels with access to the tunnels through five separate access hatches.

The water suppresion sytems and the standpipe hose stations are fed directly

from the underground fire main or from interior water supply headers. The interior water supply headers are fed through a minimum of two separate supply connections to the looped yard system. However, the water supply headers are not provided with sufficient valves to prevent a single break from impairing both the fixed pipe water suppression systems and the standpipe hose systems in each of several buildings. The applicant has installed a back-up system, which can provide. a sourc,e of fire suppression water following an SSE bu[a 7

' seismically qualifying standpipe system at strategic locations throughout the plant. These standpipe systems are provided with a manual shut off valve at the interface with the nonseismic fire protection header. A fire department l

connection is provided for each seismic standpipe system to enable a fire truck, located on site, to provide a minimum of two standpipe hose 1,ines with 75 gpm each of water for a two hour period without interruption'. The location of the seismic standpipe is such that at least one hose stream will be available for all areas of the plant which need protection. The seismic standpipe system risers are interconnected so that not more than one fire department pumper connection will be used to supply all the seismic standpipes in any one building.

The standpipe systems are consistent with the requirements of NFPA 14

" Standpipe and Hose Systems for Sizing, Spacing, and Pipe Support Requirements."

Based on our review and the applicant's commitments, we conclude that the water suppresion systems and standpipe systems meet the guidelines of Appendix A to BTP APCSB 9.5-1 and are, therefore, acceotable. .

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C. Gas Fire Sucoressions Systems Total flooding halon systems are provided for the two Computer Rooms. The halon systems are actuated by heat detection systems. The halon systems are designed to achieve a 5% concentration for 10 minutes and are designed to the ' require-

' ments of NFPA 12A, "Halogenated Fire Extinguishing Agent Systems - Halon 1301."

We have reviewed the design criteria and bases for the halon fire suppression systems. We conclude that these systems satisfy the provisions of Appendix A to

- STP ASB 9.5-1 and are in accordance with the applicable portions of NFP'A Standard No.12A and are, therefore, acceptable.

D., Fire Detection Systems The fire detection systems consist of the detectors, associated electrical power supplies, and the annunciation panels. The types of detectors used are ionization- (products of combustio'n), thermal, ultraviolet, and photoelectric.

Fire detection systems give an audible and ' visual alarm which annunciates in the plant control room. Local audible and/or visual alarms are also provided. The fire detection systems are connected to the emergency power supply. Fire detection systems will be installed in all areas having safety related equipment.

This includes the control room area, the new and spent fuel pool storage areas, and areas of cable concentration.

The fire detection systems are installed according to NFPA No. 720, " Standard for the Installation, Maintenance, and Use of Proprietary Protection Signalling Systems." Those fire detection systems which are used to actuate suppression systems have been upgraded.to a. Class A system defined in NFPA 720. ._

We have reviewed the fire detection systems to ensure that fire detectors are adequate to provide detection and alarm of fires that could occur. These systems are installed with due consideration for the use of detector spacings less than those recommended for6 smooth, unobstructed ceilings. We have also

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reviewed the fire. detection system's design criteria to ensure that they conform 3 to the applicable sections of NFPA No. 720. We conclude that the design and the installation of the fire detection systems meet the guidelines of Appendix A to BTP ASB 9.5-1 and are, therefore, acceptable.

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III. OTHEn iTEMSRELATEDTOFIREPROTECTIONPROGRAMS A. Fire Barriers and Fire Barrier Penetrations Exterior walls and walls that separate buildings are three hour fire _ rated walls. The floor / ceiling assemblies separating areas in buildings containing safe shutdown systems are either two or three hour fire rated barriers.

Interior walls are fire rated for two hours, with the exception of the walls between the electrical penetration area (Zone 2), the area outside of the personnel locks (Zone 3), and the wall between the control room proper and the peripheral rooms. For all fire areas not having a three hour fire rated assembly, we analyzed each individually witn respect to its fuel load, fire suppression and detection systems, proximity to safe shutdewn eco4ement, and ,

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concluded that two and one hour fire rated assemblies were acequaca for ae areas affected, meets sections 0.1.d and 0.1.J of Appendix "A" to BIP 9.5.1 and, therefore, is acceptable.

1 Sy referencing specific UL designs, the applicant has provided adequate documentation to substantiate the fire rating of both the fire rated barriers and the fire penetration seals used in the penetration cable trays, conduits, and piping. We have concluded that the fire . barrier and fire seal ratings meet the guidelines of Appendix A to BTP ASB 9.5-1, and, therefore, are acceptable.

l B. Fire Doors and Dameers  ;

We have reviewed the placement of fire doors and verified that all doorway openings to areas centaining safe shutdown equipment or circuits are pr'ovided with fire doors with ratings commensurate with the fire rating of the wall, except for the following: the intake structure (Zone 44) and salt water coolic tunnel (Zone 83) are not provided with fire rated doors; the three charging pu.-

rooms (Zone 50) are provided with non-rated watertight doors; and doorway between zones in the Safet/ Equipment Building are provided with non-rated 9

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watertight doors. For all areas not having a rated and labeled fire door, we .

reviewed the structure and composition of the doors and frame, the area fuel load, the fire protection features in the area, and concluded the existing unrated doors were adequate for the areas affected and, therefore, acceptable.

The licensee has provided 3-hour fire door dampers wherever ventilation ducts or All openings penetrate 3-hour fire rat'ed walls or ceiling / floor assembif es.

. ventilation ducts or openings penetrating 2-hour fire rated walls or floor / ceiling assemblies, and all such penetrations of 1-hour rated assemblies for areas containing safe shutdown equipment or circuits, are provided with 1 -hour fire dampers.

However, the ventilation ducts which penetrate the heavy concrete walls enclosing the At our request, the charging pump. rooms (Zone 50) were not provided with dampers

.et penetrations.

licensee has committed to provide 1 -hour dampers for these fire doors and dampers Based on our review and the commitments, we conclude that

, A to STP 9.5-1, will ce provided in accordance with the guidelines of App.

Section 0.1.j, and are, tnerefore, acceptable.

IV. SEIS'i!CALLY INDUCED FIRES Because the San Onofre Nuclear Generating Station is located in an area of high seismic activity, we consider the potential for fires casued by earthquakes as part of our defense-in-depth philosophy.

In the event of a fire after an earthquake, the applicant will rely on seismically qualified standpipe systems for fire suppression. The standpipe systems are supplied with water from mcbile trailer tankers fitted with pumps. The seismic standpipe systems are designed to ensure adequate coverage of all areas of the plant containing safe shutdcwn equipment.

to have a

,Since the fire detectors are non-seismic the applicant has agreed, Technical Specification that will require a plant visual inspection for fires within two hours following an earthquake. Since safe shutdown systems are protected by barriers rated at two and three hours, any fire after an earthquake should be detected by this inspection before safe shutdown systems would be affected. Based on our review and the Technical Specifications requirement, we find the detection of .

fires after an earthquake to be acceptable.

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The reactor coolant pumps contain a lube oil that could be leaked out after a seismic activity. We were concerned that this oil could be ignited and create a fire inside the containment structure.. To preclude this possibility, we required and the applicant agreed to provide an engineered oil collection system that will meet the requirements of Reg. Guide 1.29, paragraph C.2.

Based on our review and the applicants commitment, we find the seismic fire protection provisions to be adequate and, therefore, acceptable.

V. ALTEkNATE SHUTOOWN At our request..the applicant. performed a five hazards analysis, which included consideration of the potential effects of a transient exposure fire on equipment and caties (within 20 feet of each other) required for safe shutdown., An alternate shutdown system has been installed for the control room, cable spreading room, the ESF Switchgear Room (Zone 15), and one cable riser gallery (fire zone 5). Twd alternate shutdown panels are provided, which are located in, fire zone 66 in the Auxiliary Building. A fire in either the control room or spreading rooms would not je:pardize operation of the alternate shutdown panels nor would a fire in the panels cause functions in the control room or the cable spreading room. In a like manner.

an instrumentation panel, which will provide RCS and steam generator parameters, w'll be provided. This instrumentation panel will be independent of and electrically separated from the cable riser gallery (fire zone 5). Therefore, a single fire event in any of the above areas will not impair mutually redundant safe shutdown systems of division I and II simultaneously.

Our review and acceptance of the San Onofre 2 and 3 alternate shutdown system is given in Section 7.4.2 of our Safety Evaluation Report.

. l We conclude th,at the installation of the alternate shutdown systems will prec

ossibility of a single fire event in ne control room, cable spreading rooms, the

'f f e :ene 15 ESF Switchgear Room, and the fire zone 5 cable riser gallery from Therefore, we imsairing mutually redundant safe sfiutcown systems simultaneously.

M fir.d that the applicants' alternate safe shutdown system meets the requirements cf Appendix A, and also meetsSection III.L of the Appendix R to 10 CFR Part 50 and, therefore, is acceptable.

VI. P'_".';T AREAS CONTAINING REDUNDANT DIVISIONS A number of plant areas have physical arrangements where redundant division of cable / conduits and equipment are in close proximity to each other and, therefore, could be vulnerable to a single, transient fire event. Originally, the applicant was relying solely on administrative controls to preclude a fire event from taking place in affected areas. .

Sased on our experience, administrative cont'rols alone are not sufficient to prevent storage of cembustibles, or presence of ignition sources. At our request, the aoplicant committed to meet the provisions of sections III.G.2 of Appendix R to 10 CFR Part 50. Therefore, when redundant division of cable or equipment are within 20 feet of each other and not separated by a two or three hour fire rated barrier (see section III), the applicant has provided a one hour fire rated enclosure for one of the redundant divisions. In addition, a fire suppression _and detection system is provided for the area (see sections II.B and II.0). .

These areas that will have 1-hour fire rated barriers in addition to the automatic water suppression systems described in Section IIB include the following:

Cable River Galleries - Zones 12, 29, 42, 67 l Emergency HVAC Unit Room 309A - Zone 13A .

Auxiliary Feedwater Pump Room - Zone 22 Spent Fuel Pool Heat Exchangers Room.- Zone 23 . .

Electrical Tunnels - Zones 30, 53 Far. Rooms 233 & 234 - Zone 329

' Spent Fuel Fool Pump Room - Zone 36 Cra' Heat Exchangers and Piping Rooms - Zone 48 Corridor, Elev. 50'-0", Auxiliary Building - Zone 63 Corridor 442, Elev. 70',, Auxiliary Buf1 ding - Zone 72 Corridor Room 105 - Zone 78

• Sa?- Water Cooling Tunnel, Train A, Train B - Zone 83 Safety Equipment Building Elevation 8' A/C Room No. 017 - Zone 84

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. D.i.. J We have reviewed the plant areas containing redundant divisions of equipment -

and cable and conclude that, with the applicants' commitments, the fire protection meets the provisions of Appendix A and of Section III.G.2 of Appendix R to 10 CFR Part 50, and is, therefore, acceptable VII. EMERGENCY LIGHTING Eignt hour battery pack emergency lights are required for areas of the plant necessary for safe shutdown. At our request, the applicant installed self-contained

} 8-nour battery pack emergency lighting in all areas of the plant which could be manned to bring the plant to a safe cold shutdown and in access and egress routes to anc from all fire areas. .

"ased on the applicant's commitment to install 8-hour battery emergency lights, I we ccnclude that the emergency lighting meets the requirements of Appendix A and, also, the provisions of Section III.J of Appendix R to 10 CFR Part 50 and is, therefore, acceptable.

. VIII. FIRE PROTECTION FOR SPECIFIC AREAS A. Control Room The control room complex is separated from the radwaste building by a 3-hour I rated wall and from other areas by 2-hour fire rated walls, and floor / ceiling

. assemblies. Support areas within the control room complex, including offices,

! storage rooms, and laboratory and' instrument repair rooms, are separated from the control room by 1-hour fire rated walls and one 2-hour wall for the computer room.

Smoke detection has been provided for the entire control room fire area, in the ventilation system ducts, and in the main control board, and any other cabinet which contain5 redundant safe shutdown circuits. Standpipe hose stations and portable extinguishers are provided for mar.ual fire suppression activities. At I cur request, the applicant has provided water type portab,le fire extinguishers.

i There is no automatic fire suppres'si'on in the control room proper. However, at our request, the applicant ~ has committed to providing automatic sprinkler 4

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13-systems to protect the adjacent turbine laa area, the instrument. repair area, and the storage areas in the control room complex. These rooms are separated from the control room by a one hour fire. rated barrier.

As discussed in Section V, the applicant has installed an emergency shutdown panel so that alternate shutdown capability exists independent of the control room.

Based on our review and the applicant's commitments, we conclude that the control room fire protection meets the guidelines-of Appendix A to BTP ASB 9.5-1 and is, therefore, acceptable.

B.. Cable screadina Room The cable spreading rooms (one for each unit) are separated from the balance of plant by adequate fire-rated walls and floor / ceiling assemblies.

Automatic fire suppression capability is provided by a. zoned deluge system with directicnal spray nozzles designed to provide 0.15 gpm/sq. ft, based on the projected surface area of the cable trays. The water spray system har.gers are designed to withstand a design basis earthquake. Manual fire suppression capability is provided by standpipe with hose stations and oortable fire extinguishers. Portable fans are available for smoke venting. In addition, installed smoke detectors will initiate an early warning &) arm in the control room prior to sprinkler system actuation.

We were initially concerned that a fire could affect redundant shutdown systems located in the cable spreadir.g roon., However, as discussed in Section V the applicant has installed an emergency shutdown panel so that alternate shutd'own capability exists independent of the cable spreading rooms. The fir,e protection for both of the cable spreading rooms meets the guidelines of Appendix A to STP ASB 9.5-1 and is, therefore, acceptable. r r . ,, , ., -

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C. Centainment The fire hazard potential associated with the reactor coolant pumps is discussed in Section 9.5.1.4, above.

Containment fire protection features include: hose stations, fire detectors, and fire extinguishers. The applicant has committed to implement the provisions of III.G.2 of Appendix R to 10 CFR Part 50 for areas inside containment.

We have reviewed the applicant's Fire Hazards Analysis for the areas inside the containment building and conclude that the fire protection'

~ meets the guidelines of Appendix A to BTP ASB 9.5-1 and is, therefore, acceptable.

D. Other Plant Areas The applicants' Fire Hazards Analysis addresses other plant areas not

. . specifically discussed in this report. The applicant has committed to install additional detectors, portable extinguishers and hose stations, prior to fuel load. We find that the fire protection for, these areas, with the commitment made by the applicant to be in accordance with the guidelines of Appendix A to BTP ASB 9.5-1 and are, therefore, acceptable.

IX. ADMINISTRATIVE CONTROLS AND FIRE BRIG'ADE The administrative controls for fire protection consists of the fire protection organization, tha fire brigade training, the controls over combustibles and ignition source, the prefire plans and procedures for fighting fires and quality assurance.

The applicant has agreed to implement the fire protection program contained in the staff supplemental guidance " Nuclear plant Fire Protection Functional Responsibili- '

ties, Administrative Controls and Quality Assurance," dated August 29, 1977, including (1) fire brigade training, (2) control of combustibles, (3) control of ignition sources (4) fire fighting procedures, and (5) quality assurance.

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i The applicants will implement the plant administrative controls and pro- j

cedures before fuel loading.

4 The applicants will have a five-man fire brigade which meets our guidelines, ,

and is, therefore, acceptable.

Initially, the applicant had intended that their five man brigade would utilize self-contained air masks which would be placed at strategic locations throughout t.5e j

l Plant. These units would not be reserved for fire brigade use. At our request, the applicant ha's placed five self-contained, positive pressure air masks, which will be i reserved for fire brigade use, at each of *two locations. Additional masks are

,available at the control room for general plant use.

'de conclude that, with the above modifications and commitments, the five man fire brigade equipment and training will conform to the recommendations of the National Fire Protection Association, to Appendix A to BTP ASS 9.5-1, and to our supplemental staff guidelines and, therefore, are acceptable. .

. TECHNICAL SPECIFICATIONS ,

The applicant has committed to follow our Standard Technic O Specifications.

We find this acceptable.

t XI. APPENDIX R STATEMENT On May 23, 1980, the Commission issued a Memorandum and Order (CL 1-80-21) which states that: "The combination of the guidance contained in Appendir. A to BTP 9.5-1 and the requirements set forth in this rule . define.the essential. elements.for..an . t acceptable fire protection program at nuclear power plants docketed for Construction Permit prior to July 1,1976, for demonstration of compliance with General Design Criterion 3 of Appendix A to 10 CFR Part 50." On October 27, 1980, the Commission approved a rule concerning fire protection. The rule and its Appenoix R were developed to establish the minimum acceptable fire protection requirements necessary

. to resolve certain areas of concern in. contest between the staff and Itcensees of

, plants operating prior,to January 1,1979.

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Although this fire protection rule does not apply to the San Onofre Unit 2 and 3 '

nuclear facility, based on our review and evaluation of the San Onofre fire protection and the applicants' commitments, we conclude that tha San Onofre fire protection program will meet the following three issues identified in Appendix R.

1.Section III.G., Fire Protection of Safe Shutdown Capability

2.Section III.J. , Emergency Lighting

3.Section III.O., Oil Collection System for Reactor Coolant Pump.

The implementation schedule will be in accordance with the requirements of the rule.

Based on these cunmitments and our evaluation, we conclude that San Onofre Unit 2 ano

• fire protection program will meet all the requirements of Appendix R to 10 CFR Part 50 when the connitted modifications have been completed, meets the require-ments of GDC 3 'and therefore is acceptable. .

XII. CONCLUSION We conclude that a fire occurring in any area of the San Onofre Nuclear Plant, Unit 2 and 3, with all proposed modifications accomplished, will not prevent the units from being brought to a controlled safe colo shutdown. Further, such a f t,re would not cause the release of significant amounts of radiation.

. , We find that the Fire Protection Program for San Onofre 2 and 3, with the improvements and modifications committed by the applicant to be implemented prior to fuel loading, will meet the guidelines contained in Appendix A to STP.ASB 9.5-1, and meets the General Design Criterion 3 and is, therefore, acceptable.

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Southern California Edison Company y1

• O SQX 000 2244 W ALNUT GROVE AVt NUE RO$tMEAC C ALIFORNI A 91770 K. P. 0 A$ KIN

....u...~ocs............ July 22, 1982 Tfkt. 0~E

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Director, Office of Nuclear Reactor Regulation Attention: Mr. Frank Miraglia, Branch Chief Licensing Branch No. 3 U. S. Nuclear Regulatory Commission Wa shington, D.C. 20555 Gentlemen:

Subject:

Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station Units 2 and 3 The purpose of this letter is to satisfy license condition 2.C.(14)c -

of the San Onofre Nuclear Generating Station Unit 2 (SONGS 2) Operating -

Li cense, NPF-10. License condition 2.c.(14)c requires that Southern ~

California 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 the Standard Review Plan (NUREG-0800, dated July,1981).

To satisfy this requirement, SCE has compared the SONGS 2 and 3 fire protection program witn the specific acceptance criteria which are detailed in l Branch Technical Position (BTP) CMEB 9.5-1 and Regulatory Guides 1.78 and

! 1.101. In performing this comparison, SCE reviewed all relevant documents

' which discuss the SONGS 2 and 3 fire protection program. Included in this review were the Fire Hazards Analysis (FHA), the Final Safety Analysis Report (FSAR), responses to NRC questions relating to fire protection, the Safety Evaluation Report (SER, NUREG-0712) including SER Supplements, and Appendix B of the Unit 2 Technical Specifications.

In conducting the comparison, several inconsistencies were noted between statements made in the SER and information conveyed in the FSAR, FHA, i responses to WRC questions and other relevant communications with the NRC staff. Because the SER is indicative of the NRC staff's perception of the SONGS 2 and 3 fire protection program, SCE considers that it is important to highlight these inconsistencies so that the comparison of the SONGS 2 and 3 fire protection program with Section 9.5-1 of the Standar d Review Plan can be assessed by the NRC staff from the same standpoint as it was produced.

Enclosure 1 identifies statements in the SER rela' ting to SONGS 2 and  !

3 fire protection whicn are inconsistent witn tne information provided by SCE in the FSAR, FHA and other relevant communications with the NRC staff.

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Mr. Frank Miraglia July 22, 1982 comparison of the SONGS 2 and 3 fire protection program with the acceptance criteria of Section 9.5-1 of the Standard Review Plan is discussed in the following paragraphs.

Corparison With BTP 9.5-1 (July,1981)

Southern California Edisoi provided a comparison of the San Onofre Units 2 and 3 fire protection program with the previous BTP 9.5-1 (August, 1976) in the Fire Hazards Analysis (FHA). This review against the current BTP 9.5-1 (July,1981) identifies and describes only those items where SCE has provided equivalent protection by alternate means, clarification of SCE's position is required, or clear deviation from new requirements exist, which were not previously covered in the Fire Hazards Analysis.

BTP 9.5-1 (July,1981) presents recommended guidelines for acceptable means of satisfying the requirements of General Design Criterion 3 of Appendix A to 10 CFR 50. Previously, guidelines were provided in Appendix A to BTP 9.5-1 (August, 1976) and its predecessors. Tne guidelines contained in Appendix A to BTP 9.5-1 (August,1976) differentiated between plants which were under construction or operating before July 1,1976 (e.g., SONGS 2 and 3) and those which were docketed for construction after July 1,1976. The current BTP 9.5-1 incorporated Appendix A of the old 9.5-1 but makes no distinction between old and new plants. The current 9.5-1 guidelines pertaining to building design (item C.5.a) are more specific concerning the provision of three hour fire rated barriers and physical separation of redundant trains of equipment than were the previous guidelines which took into account plant vintage.

Because of the vintage of SONGS 2 and 3 and the advanced stage of construction when the current BTP 9.5-1 guidelines were produced, and because the design was based on guidelines which existed at the time, SCE has not provided three hour fire rated barriers in all areas where they are recommended in position C.5.a nor have separate cable spreading rooms and tunnels been provided for redundant trains. However, fire barriers have been provided, as detailed in the Fire Hazards Analysis, which have been reviewed by the staff with respect to fire loading and safe shutdown capability and found to be acceptable in meeting the requirenents of General Design Criterion

3. Additionally, the requirements of position BTP 9.5-1 C.5.b(1) were met by incorporating the design features described in C.5.b(2) and by the provision of alternate shutdown capability independent of the control room and the cable spreading room should fire occur in either of these areas.

1 Therefore, Southern California Edison considers that SONGS 2 and 3 meets the acceptance criteria pertaining to building design contained in BTP 9.5-1 (July,1981) C.5.a because SCE has provided acceptable equivalent fire protection which has been reviewed with regard to Appendix A to BTP 9.5-1 (August,1976), follows the guidelines of BTP 9.5-1 (July,1981) C.5.b(2)c and 10 CFR 50, Appendix R Section Ill.G.2 and, a: such, satisfies the requirements of General Design Criterion 3 of 10 CFR 50, Appendix A.

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Mr. Frank Mira91 ia July 22, 1982 The six BTP 9.5-1 items wherein the SCE fire protection program differs from current guidelines are described b? low:

1. BTP 9.5-1 Item C.3.b Item C.3.b recommends that a five man Fire Brigade be provided, of which the 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. Previous guidelines, such as Appendix A to BTP 9.5-1 (August 1976), did not specify the requirement for the Fire Brigade to be able to assess the effects of fire on plant safe shutdown

/ capability. SCE has currently under contract a full time bg.. professional Fire Brigade consisting of five members on each shif t.

The brigade members are all certified Fire Fighters and have had

/ training in plant systems in order to develop basic skills with which to assess the effects of fire on safe shutdown capability.

All members of the Fire Brigade will continue to participate in training designed to develop and keep current their skills with respect to fire suppression and the assessment of the effects of fire on safe shutdown. In order to insure an expert level analysis j of safe shutdown capability degradation, each shift will have an Assistant Control Operator (ACO. Referred to as A0 in Technical J Specification 6.2.2) to serve as the sixth member of the Fire Brigade. The ACO will respond with the Fire Brigade in the event of a fire. The ACO will not participate in actual fire suppression activities, but rather perform the function of assessing the effects of the fire and fire suppressants on safe shutdown capability and communicating the same to the Watch Engineer in the Control Room.

SCE considers that this arrangement provides for the best of effective fire suppression and accurate determination of the effects of fire and fire suppression on plant safe shutdown capability.

2. BTP 9.5-1 Item C.5.a(5)

Item C.5.a(5) recomends that areas protected by total flooding gas suppression systems have electrically supervised self-closing fire doors. Previous guidelines did not specify electrical supervision of the doors. Unit 2 and Unit 3 Coquter Rooms located on the 30'

- elevation of the Auxiliary Building are protected by total flooding Halon systems. Doors to the co@ uter rooms are not electrically supervi sed. Electrical supervision is considered unnecessary i because the computer rooms are in the control room area close to the continuously nanned operator consoles.

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3. BTP 9.5-1 Item C.6.a(1) l Item C.6.a(1) recomends that fire detection systems be provided for i all areas that contain or present a fire exposure to safety related S'l equipment. Previous guidelines were not specific as to the

{ installation of fire detection in all areas containing safety

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__ -- . . _. - . - ~ -a Mr. Frank Miraglia July 22, 1982 related equipment. Consistent with previous guidelines, SCE installed fire detection in areas containing equipnent required for safe shutdown based on the fire hazards present in the fire zone.

Fire detection systens and safety related equipment in each fire zone are detailed in the Fire Hazards Analysis (FHA). As previously reported in the FHA which was reviewed by the staff and found to be acceptable, 23 low fire severity fire zones which contain safe shutdown or other safety related equipment are not equipped with fire detection. Additional fire detection is considered unnecessary because of the low fire loading in these zones.

4. BTP 9.5-1 Item C.7.f Item C.7.f recommends that redundant safety related panels remote from the cont ol room be separated from each other by a minimum of three hour fire rated barriers. Additionally panels providing remote shutdown capability should be separated from the control room complex by a minimum of three hour fire rated barriers. SCE has provided alternate safe shutdown capability independent of the control room and cable spreading room should fire occur in these areas. As noted in the FHA, fire zone 66 which contains the train A and train B remote shutdown panels, is separated from the control A; jroom complex by two hour fire rated barriers, which are adequate .

D Jconsidering the fire loading. The train A and B remote shutdown panels are not separated from each other by a tnree hour fire rated S'- barrier. However, tnese panels would only be required for safe i

y f .jb. j shutoown in the event of a fire in the control room or cable

, sd  ; spreading room. The simultaneous occurrence of independent fires in separate plant areas is not postulated. Separation of the remote 43

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shutdown panels from each other is considered unnecessary because safe shutdown capability would still exist in the control room in the event of a fire in zone 66.

5. BTP 9.5-1 Item C.7.i Item C.7.i suggests that automatic fire suppression systems, installed to combat diesel generator fires, De designed for operation when the diesel generator is running without affecting the iM ,/ diesel. This criteria was not part of previous guidelines for fire f suppression systems in diesel generator areas. The San Onofre Unit 2 and 3 diesel generators are not designed and have not been tested to operate while being sprayed by the sprinkler system. In the event that one diesel generator is disabled by fire and i

operation of the sprinkler system, the second unaffected diesel generator would provide for safe shutdown of the plant.

6. BTP 9.5-1 Item C.7.k Item C.7.k recommends that. redundant trains of safety related pumps be separated by three hour fire rated barriers. Appendix A to BTP 9.5-1 (August,1976) provided guidance only concerning the p separation of safety related pumps from other areas of the plant.

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! Mr. Frank Miraglia July 22, 1982 y As indicated in the Fire Hazards Analysis, the auxiliary feedwater My pumps are not separated from each other by a three hour fire rated Y p'  :

i barrier. However, cabling to the train B pump is wrapped with a one

/ hour fire retardent blanket and the auxiliary feedwater pump room is protected by a pre-action sprinkler system. Additionally, a curb to I

prevent the spreading of oil fires separates the train A and B floor areas and a missile shield separates the pumps. SCE considers that these features provide fire protection equivalent to that recommended by item C.7.K.

Two items in BTP 9.d-1 were identified where clarification of SCE's position relative to the guidelines is in order. These are described below:

1. BTP 9.5-1 Item C.6.b(6)

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 ik fire rated barriers. As described in the Fire Hazards Analysis, the

(/ SONGS 2 and 3 fire pumps are not separated by three hour fire rated ,

barriers. However, in the event that the fire pumps are disabled by a fire, fire fighting water would still be available to all areas of the plant containing safe snutdown equipment by using the fire truck and/or the intertie between the Unit 1 and Units 2 and 3 fire mains.

2. BTP 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 ano that there is a reasonable assurance that it will withstand a safe shutdown eartnquake (SSE). SCE has provided a reactor coolant pump oil collection system which will prevent the spread of reactor coolant pump oil fires during normal operation and design basis accident conditi ons. It is designed to withstand a safe shutdown earthquake j , in that it will not prevent the functioning of safe shutdown equipment following an SSE. This interpretation of the requirement to withstand a safe shutdcwn eartnquake is consistent with paragraph C.2 of Regulatory Guide 1.29 which is referenced by 10 CFR 50, Appendix R, Section 111.0 which addresses the requirements for oil collection systems for reactor coolant pumps.

Comparison With Regulatory Guides 1.78 and 1.101 Southern California Edison has reviewed the SONGS 2 and 3 fire -

protection program and has found that it complies with the recommendations relating to fire protection programs contained in Regulatory Guides 1.78 and 1.101.

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Mr. Frank Miraglia July 22, 1982 The information contained in this letter is submitted to satisfy l License Condition 2.C.(14)c. It is Southern California Edison's belief that i although the SONGS 2 and 3 fire protection program differs, as noted, from the specific recommendations of BTP 9.5-1 (July,1981) it provides equivalent fire protection which has been previously reviewed by NRC staff and found to satisfy General Design Criteria 3 and 5 of 10 CFR 50, Appendix A.

If you have any questions regarding this information, please call me.

Very truly yours, Enclosure cc: "

darry Rood, NRC (to be opened by addressee only)

R. H. Engelken, NRC Region V s

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o-ENCLOSURE 1 SER Statements Which are Inconsistent With Information Provided by SCE ITEM SER LOCATION SER STATEMENT

% REMARKS

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1 Pages 9-20. "All valves in the fire Paragraph two. Header isolation valves for protection water supply system i seismic standpipes and locked open i First sentence. are electrically supervised manual ~ isolation valves to deluge except for the post indicator systems are not electrically l valves, which are in the supervi sed.  !

underground yard main system."

2 Pages 9-20, "* Sprinkler system installed at 9-21. our request."

i For the reasons stated in the l response to FQ015.55, an List. -d Control Room Complex - Zone 31*3 jautomatic suppression system is D( ", ~ ... - Turbine Lab W not considered necessary for these

- Instrument Repair Area bl areas. No commitment was made by

- Storage, Rooms 249, 251, 252 ' SCE to install an automatic

! suppression system. Additionally

the Instrument Repair Area is now

$theTechnicalSupportCenter

-(TSC).

3 Pages 9-21. "At our request, the applicants First paragraph The responses to questions have installed standpipe hose FQ015.29 and FQ015.31 comitted following list. stations.in _five zones 4, 10, SCE to install standpipes in fire Second sentence. 28 and 45."

zones 4 and 10 respectively. As stated in the responses to

.-c.l . m . FQ015.31 and FQO15.57, the

?p" 'A equivalent fire severity in zones 28 and 45 is one minute and the

..V C zones do not contain any j equipment or cabling required for safe shutdown. Portable hand held extinguishers are provided c

' and considered adequate. No commitment was made to install standpipes in zones 28 and 45.

4 Pages 9-24. "However, the ventilation ducts Paragraph one, SCE has not committed to, nor nave which penetrate the heavy fire dampers been installed in Last sentence. concrete walls enclosing the these duct penetrations.

charging pump room (Zone 50) were not provided with dampers.

At our request, the applicants /

have committed to provide 1-1/2 hour dampers for these duct penetrations."

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ITEM SER LOCATION SER STATEMENT REMARKS 5 Pages 9-27. "However, at our request, the See remarks to Item 2.

Paragraph one, applicants have committed to Second sentence. providing automatic sprinkler

, systems to protect the adjacent turbine lab area, instrument repair area, and storage areas in the control room complex."

6 Pages 9-21. " Corridor 442, Elevation 70', This statement is consistent with List. Auxiliary Building - Zone 72*" information provided by SCE in the FHA. However, the FHA incorrectly identified corridor i

i \ e 442, instead of corridor 401, as

\; containing the redundant cabling

[/ ,,}y,3 {.Lfor the HVAC batteries' exhaust fans. Corridor 401 contains the cabling and the sprinkler system. The FBA is being amended

' accordingly. This should be noted in the SER.

7. Pages 9-20, "The areas that have been To clarify the statement in the 9-21. equipped with water suppression SER, the following should be List. systems include the following:" , noted: Water suppression systems

- Fan Rooms 219 and 221, ,S are provided for the charcoal Charcoal Filter - Zone 32A

• filters only. No area sprinklers

- Emergency A.C. Unit Room 308, are provided in these zones. Tne Charcoal Filters - Zone 9 charcoal filter deluge systems are

- Emergency A.C. Unit Room 301, manually actuated.

Charcoal Filters - Zone 9

- Piping Penetration Area (El 30') Charcoal Filter -

Zone 28

8. Page 9-22. " Fire detection systems will be Paragraph 5.

. Fire detection is installed in installed in all areas having y zones according to the fire Second last safety related equipment." y hazards present. As ncted in the

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FHA, 23 low severity fire zones conta 4ing safe shutdown or other safety related equipment are not equipped with fire detectors.

PSmith: 4438