ML020220119

Part 1 of 2, San Onofre Nuclear Generating Station, Units 2 & 3, Proposed Change Number NPF-10/15-517, Supplement 1, Revision of Facility Operating License

ML020220119
Person / Time
Site:	San Onofre
Issue date:	01/11/2002
From:	Nunn D Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
-nr
Download: ML020220119 (140)

Text

- SOUTHERN CALIFORNIA

._EDISON Dwight E. Nunn Vice President An EDISON INTERNATIONAL"' Company January 11, 2002 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

Subject:

Docket Nos. 50-361 and 50-362 Proposed Change Number NPF-10/15-517, Supplement 1 Revision of Facility Operating License San Onofre Nuclear Generating Station, Units 2 and 3

Reference:

Letter from Dwight E. Nunn (SCE) to the Document Control Desk (NRC) dated March 21, 2001;

Subject:

Docket Nos. 50-361 and 50-362 Proposed Change Number NPF-10/15-517 Revision of Facility Operating License, San Onofre Nuclear Generating Station, Units 2 and 3 Gentlemen:

Enclosure 1 provides additional information to that included in the referenced March 21, 2001 submittal, which requested closure of completed license conditions. Enclosure 2 includes replacement operating license pages to substitute for those provided in the Reference submittal. These replacement operating license pages identify those license amendments which closed other license conditions, not being proposed for closure by the above referenced submittal. SCE is making no formal commitments that would derive from NRC approval of the proposed amendment supplement.

The 10 CFR 50.92 "No Significant Hazards Considerations" evaluation of Proposed Change Number NPF-1 0/15-517, submitted with the referenced letter, is not impacted by this supplement.

Ifyou have any questions regarding this additional information, please contact me or Mr. Jack L. Rainsberry (949) 368-7420.

Sincerely, Enclosures cc: E. W. Merschoff, Regional Administrator, NRC Region IV J. N. Donohew, NRC Project Manager, San Onofre Units 2, and 3 C. C. Osterholtz, NRC Senior Resident Inspector, San Onofre Units 2 & 3 P. O. Box 128 San Clemente, CA 92674-0128 949-368-1480 Fax 949-368-1490

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA EDISON COMPANY, ET AL. for a Class 103 Docket No. 50-361 License to Acquire, Possess, and Use a Utilization Facility as Part of ) Amendment Application No. 201 Unit No. 2 of the San Onofre Nuclear ) Supplement 1 Generating Station )

SOUTHERN CALIFORNIA EDISON COMPANY, ET AL. pursuant to 10 CFR 50.90, hereby submit information in support of Amendment Application No. 201. This information consists of responses to NRC requests for additional information on Proposed Change No. NPF-10-517 to Facility Operating License NPF-10. Proposed Change No. NPF-10-517 is a request to administratively update the Facility Operating License by deleting completed license conditions.

K THURBER Cowm**M 1295266 State of California "Mm PUMN California Sm Diego County County of San Diego ED r"W-mr-mr-l"

1. • CommBoaW23=51 Subscribed and sworn to (or affirmed) before me this ______"_day of

-2 S_*___*,200 By Dwight Nunn Vice Pre i ent Nota Public

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA )

EDISON COMPANY, ET AL. for a Class 103 ) Docket No. 50-362 License to Acquire, Possess, and Use )

a Utilization Facility as Part of ) Amendment Application No. 186 Unit No. 3 of the San Onofre Nuclear ) Supplement 1 Generating Station )

SOUTHERN CALIFORNIA EDISON COMPANY, ET AL. pursuant to 10 CFR 50.90, hereby submit information in support of Amendment Application No. 186. This information consists of responses to NRC requests for additional information on Proposed Change No. NPF-10-517 to Facility Operating License NPF-15. Proposed Change No. NPF-10-517 is a request to administratively update the Facility Operating License by deleting completed license conditions.

FRANCES M. THURBER State of California ConiiRon 0 129S266 County of San Diego Son rkM County o

Subscribed and sworn to (or affirmed) before me this +/-Lday

-LAof

":By:

Dwight E. n Vice Presiden NotarubIr

ENCLOSURE 1 Enclosure 1 PCN-517, Supplement 1 Additional Information Supporting Proposed Change Number (PCN) NPF-10/15-517 "Revision of Operating License" San Onofre Nuclear Generating Station Units 2 and 3

1. UNIT 2 LICENSE CONDITION 2.C.(19)f. 1 CONTROL ROOM DESIGN (TMI ISSUE I.D.1)

The following reference provides additional information for closure of this license condition.

NRC to SCE letter dated October 5, 1982 "NRC Inspection Reports 50-361/

82-27 and 50-362/82-19" (PCN-517 Reference No. 36)

Item 2.a, "(Closed) Item I.D.1, Control Room Design Review (Low Power License Condition 2.C.(1 9))," confirmed the inspector verified that all requirements of the low power operating license relative to this item had been completed in the Unit 2 control room and confirmed that no items of noncompliance or deviations were identified.

2. UNIT 3 LICENSE CONDITION 2.C.(17)c. CONTROL ROOM DESIGN REVIEW (TMI ISSUE I.D.1)

The following references provide additional information for closure of this license condition.

NRC to SCE letter dated October 5, 1982 "NRC Inspection Reports 50-361/

82-27 and 50-362/82-19" (PCN-517 Reference No. 36)

Item 3c, "(Open) Item I.D.1, Control Room Design Review," confirmed that all items had been satisfactorily resolved, except for: the primary makeup pump flow controller being mislabeled, an error in the placement of Technical Specification limit indicating arrows for Containment Pressure and Refueling Water Storage Tank Level, fuel load pattern recognition information needed to be incorporated into emergency operating procedures, operator training in the use of the process computer was required, and the open/closed legends for hydrogen purge control on the HVAC panel were reversed.

NRC Inspection Reports 50-361/82-39 and 50-362182-31 dated December 7, 1982 (PCN-517 Reference No. 34)

Item 14.b, "(Closed) Item I.D.1 - Control Room Design Review," confirmed the inspector verified the five items discussed in Inspection Report 50-362/82-19 (above) were satisfactorily completed prior to fuel load.

3. UNIT 2 LICENSE CONDITION 2.C.(19)n. ADDITIONAL MONITORING INSTRUMENTATION There are three sets of monitors associated with this license condition: 7865, plant vent and containment purge monitors; 7870, condenser evacuation system monitors; and 7828 containment purge only monitors. The following references provide additional information for closure of this license condition.

NRC to SCE letter dated March 2, 1982 "NRC Inspection Report 50-361/82 09" (Reference A)

Enclosure 2 of SCE to NRC letter dated February 1, 1982 (this letter is Enclosure 1 of NRC inspection report 361/82-09) section II "CONDENSER EVACUATION SYSTEM" describes the condenser evacuation system monitor 7870 which provides the capability for iodine and fixed particulate sampling.

NRC to SCE letter dated March 4, 1983 "NRC Inspection Report 50-361/83 08" (Reference B)

Section B. "Sampling and Analysis of Plant Effluents" discusses the procedure for particulate and radioiodine sampling using the wide range gas monitors 7865 and 7870 in a post accident situation. This inspection determined that there were inadequate preparations for the onsite analysis of charcoal or particulate samples, that criteria for offsite shipments was inconsistent, and that procedures were inadequate regarding direction for higher activity particulate and radioiodine samples being sent offsite for analysis.

NRC to SCE letter dated November 16, 1983 "NRC Inspection Report No.

50-361/83-37" (Reference C)

This inspection report addressed sampling and analysis issues raised in Reference B. In section d of this report "Additional Review II.F.1, Attachment 2" the inspector indicated that the system did not appear to meet the intent of NUREG-0737, Item I1.F.1-2, in that a significant time delay was necessary before one person could be expected to retrieve a sample with acceptable exposure limits. This issue was identified as open item 50-361/83-37-01.

2

NRC to SCE letter dated March 7, 1986 "NRC Inspection Report No. 50 361/86-02" (Reference D)

In section 2 "Licensee Action on Previous Inspection Findings (Closed) Followup (50-361/83-37-01)" the inspector verified that procedure S01 23-111-8.10.23 was revised to address manpower requirements for post accident sample collection, and closed this item. The current practice for handling high range iodine and particulate WRGM samples continues to utilize procedure S0123-111-8.10.23.

SCE to NRC letter dated February 3, 1982 "Implementation Program for Radiation Monitors" San Onofre Nuclear Generating Station Units 2 and 3 (Reference E)

Enclosure 4 of this letter discusses an SCE proposal to utilize the containment atmosphere monitoring system, gaseous radiation monitors 7804 and 7807, rather than provide direct monitoring on the purge lines.

NUREG-0712 Supplement No. 5 "Safety Evaluation Report related to the operation of San Onofre Nuclear Generating Station Units 2 and 3" dated February 1982 (Reference F)

Section 11.3 approved Interim use of the containment atmosphere monitoring system and associated sampling media in lieu of the SCE planned response to NUREG-0737 of monitoring directly on the purge lines. Requirement for capability to perform continuous monitoring and sampling of the containment purge exhaust directly from the purge stack after the first refueling outage was subsequently documented and fulfilled by installation of containment purge monitors 7828 per Unit 2/3 license conditions 2.C.(17) / 2.C.(1 5) "Purge System Monitors (Section 11.3, SER, SSER # 5)."

4. UNIT 3 LICENSE CONDITION 2.C.(23) FUEL ASSEMBLY SHOULDER GAP CLEARANCE The following references provide additional information for closure of this license condition.

SCE to NRC letter dated March 11, 1991 "Fuel assembly Shoulder Gap Adequacy" (Reference G)

This letter requested closure of license condition 2.C.(23) based on the acceptable shoulder gap analysis results for the first five cycles. Further, SCE determined that the Fuel Element Assembly (FEA) shoulder gap analysis results were acceptable for the 16 x 16 fuel design with a FEA shoulder gap clearance of 2.382 inches (vs. 1.332 inches initially). SCE committed to continue to evaluate the adequacy of the FEA shoulder gap as part of the San Onofre Units 2 and 3 reload analyses.

3

NRC to SCE letter dated March 26, 1991 "Fuel Assembly Shoulder Gap Adequacy" (Reference H)

Responded to the March 11, 1991 SCE letter above, providing NRC concurrence that the shoulder gap clearance provided was adequate for the design life of the fuel and confirming that license condition 2.C.(23) had been met.

5. UNIT 2/3 LICENSE CONDITIONS 2.C.(16)12.C.(14) RADIOACTIVE WASTE SYSTEM The following references provide additional information for closure of these license conditions.

SCE to NRC letter dated May 1, 1985 "San Onofre Nuclear Generating Station Units 1, 2, and 3" (Reference I)

This letter advised that the SCE San Onofre contract with Chem-Nuclear, Inc. for the, NRC interim approved Process Control Program (PCP) had expired on April 1, 1985 and that Chem-Nuclear had been replaced by Nuclear Packaging (NuPac), Inc. as the vendor of wet radwaste treatment services at the San Onofre Nuclear Generating Station. This letter also advised that the NuPac topical report, P-02-NP, which addressed their dewatering system, had been submitted for NRC review in August 1984. This (May 1, 1985) letter requested NRC approval of topical report, TP-02-NP for SCE use of the NuPac dewatering system, as described in the NuPac topical report.

NRC to SCE letter dated June 11, 1985 "Interim Approval of Dewatering of Spent Resin" (Reference J)

Responded to the May 1, 1985 SCE letter above, granting interim approval effective until the NRC review of NuPac's licensing topical report would be completed.

NRC to SCE letter dated August 10, 1995 "Final Draft of the NRC Safety Evaluation Report (SER) on San Onofre Improved Standard Technical Specifications (STS)" (Reference K)

Provided a final draft of the NRC safety evaluation report (SER) on SCE license amendment request PCN-299 dated August 25, 1994, for conversion of the San Onofre Nuclear Generating Station (SONGS) Unit 2 and 3 Technical Specifications to the improved standard Technical Specifications. This SER's discussion of the Process Control Program (PCP) for waste solidification, on page 69, refers to the San Onofre Licensee Controlled Specifications (LCS) and 4

Topical Quality Assurance Program (TQAM) PCP descriptions. The SER concludes that the regulatory controls for the San Onofre Topical Quality Assurance Manual (TQAM) provided sufficient control of the requirements and that removing PCP provisions from the Technical Specifications was acceptable.

NRC to SCE letter dated February 9, 2000 "NRC Inspection Report No. 50 361/2000-01: 50-362/2000-01" (Reference L)

Inspection report item Ric concluded that SCE met regulatory requirements associated with the solid radioactive waste management program.

San Onofre Units 2 and 3 Licensee Controlled Specifications (LCS)

Sections 5.0.103.2.2 Process Control Program (PCP) (Reference M)

LCS 5.0.103.2.2 provides the current PCP control to ensure that processing and packaging of solid radioactive wastes at San Onofre is accomplished in a manner to ensure that all regulatory compliance requirements are met.

6. UNIT 3 LICENSE CONDITION 2.C.(22) AUXILIARY BUILDING VENTILATION SYSTEM The following reference provides additional information for closure of this license condition.

Design Change Package (DCP) 790.1 dated August 7, 1984 Design Change Package (DCP) 790.1 (Reference N)

Design changes to block potential release paths and provide better Auxiliary Building ventilation air flow were installed by implementation of Design Change Package (DCP) 790.1.

7. UNIT 2 LICENSE CONDITION 2.C.(19)e PROCEDURES FOR VERIFYING CORRECT PERFORMANCE OF OPERATION ACTIVITIES The following reference provides additional information for closure of this license condition.

NRC to SCE letter dated March 15, 1982 "NRC Inspection Report No. 50 361/82-10" (PCN-517 Reference No. 31)

Inspection report, item 3b closed this license condition.

5

REFERENCES (References are listed in the sequence used in this Supplement)

36. NRC to SCE letter dated October 5, 1982 "NRC Inspection Report 50-361/82-27" (PCN-517 Reference No. 36)

34. NRC Inspection Report 50-362/82-31 dated December 7, 1982 (PCN-517 Reference No. 34)

A. NRC to SCE letter dated March 2, 1982 "NRC Inspection Report 50-361/82-09" B. NRC to SCE letter dated March 4, 1983 "NRC Inspection Report 50-361/83-08" C. NRC to SCE letter dated November 16, 1983 "NRC Inspection Report 50-361/83-37" D. NRC to SCE letter dated March 7, 1986 "NRC Inspection Report 50-361/86-02" E. SCE to NRC letter dated February 3, 1982 "Implementation Program for Radiation Monitors" San Onofre Nuclear Generating Station Units 2 and 3 F. NUREG-0712 Supplement No. 5 "Safety Evaluation Report related to the operation of San Onofre Nuclear Generating Station Units 2 and 3" dated February 1982 G. SCE to NRC letter dated March 11, 1991 "Fuel assembly Shoulder Gap Adequacy" H. NRC to SCE letter dated March 26, 1991 "Fuel assembly Shoulder Gap Adequacy" I. SCE to NRC letter dated May 1, 1985 "San Onofre Nuclear Generating Station Units 1, 2, and 3" J. NRC to SCE letter dated June 11, 1985 "Interim Approval of Dewatering of Spent Resin" K. NRC to SCE letter dated August 10, 1995 "Final Draft of the NRC Safety Evaluation Report (SER) on San Onofre Improved Standard Technical Specifications (STS)"

L. NRC to SCE letter dated February 9, 2000 "NRC Inspection Report No.

50-361/2000-01: 50-362/2000-01" 6

M. San Onofre Units 2 and 3 Licensee Controlled Specifications (LCS) Sections 5.0.103.2.2 Process Control Program (PCP)

N. Design Change Package (DCP) 790.1 dated August 7,1984 Design Change Package (DCP) 790.1

31. NRC to SCE letter dated March 15, 1982 "NRC Inspection Report No. 50-361/82 10" (PCN-517 Reference No. 31) pcn5l7raild 7

Reference #36 o UN=T.D STATES3 "NUCLEAR REGULATORY COMMISSICN NUCU REG~ON V A60 MARIA CANE. SUITE 210 146 WALNUT CSEEK, CALIFORNIA 945-96 OCT 7 1982 NUCLEARUCISNG Cctober 5, 11982 occket Nos. 50-361 50-362 Southern California Ediscn Company P. 0. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 Attention: Dr. L. T. Papay, Vice President Advanced Engineering Gentlemen:

Subject:

NRC Inspection of San Onofre Units Nos. 2 and -3 This refers to the routine inspecticn conducted by Messrs. C. F. Kirsch.

and M. Mendonca of this office on September 5-17, 1982 of ac-ivities authorized by NRC License No. NPF-10 and NRC Ccnstruction Pe.it No. CPPR-98, and to the discussion of our findings held with Mr. W. C. Moody and other members of the Southern California Edison Company s:aff at the conclusion of the inspection on September 17, 1982.

Areas examined during this inspection are descri ed in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspectors.

No items of noncompliance with NRC requirements were identified within the scope of this inspection.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days.

of the date of this letter. Such application must be consistent with the requirements of 2.790(b)(1).

Southern California Edison Company October 5, 1982 Should you have any questions concharning this inspection, we will be glad to discuss them with you.

Sincerely,

.* 7. W. Bishcp, ch0e Reactor Pr--ects Branch Nc. 2

Enclosure:

NRC Inspection Report Nos. 50-361/82-27 50-362/82-19 cc w/o enclosure:

R. Dietch, SCE cc w/enclosure:

H. B. Ray, SCE (San Clemente)

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Reference #34

.,840223G- '

U.S.N,-LEAR REGULATORY COIUSSIC

-39I P

Riport 361/82~-31_

tXo3 500- 362182 DF }PConstruction Permit No. CPOR-98 Docket No. 50-361: 50-362 Licanse No. NP_,_- _ -_ 5 Safeguards Group Licansee: Southern California Edison (SCE) Ccm~anX P. 0. Box 800 2244 Walnut Grove Avenue Rosemead. C1ifnroria 91770 Facility Hama: _Rosemead- Califnrnia 91770 Inspection at: San Onofre - U1nit ? and Unit 3 Inspection conducted: October 26 through November & 9g2 Inspectors: .h ,

Senior Resi L

t Inspector, Unit 2

________ -7xi~

Oate Sign.O ACbaffee, Dat SiFpgnt 2rn -2A

"_7__

Approved by: 3 DLa a ie Di irsch,,r Chief, F0 Reactor/rojecsec Section ,o.

""eactor Projects Branch No. 2 Sum*ary:

Insoection on ctober 26. 1982 through November 28, 1982/e8,ott Nos.

20-361/

82-39, 50-3621-31) of the Unit 2 and 3 Areas Inspected: Routine, unannounced resident inspection areas: followup Operations and Startup Test Programs Including the following on Inspector identified items; operational safety verification; monthly sur-eillance monthly maintenanc- observations (Unit 2); Review of Plant Operations observations; (Unit 2); Power Ascension Test Aitnessfng (Unit 2); Transient Test Witnessing and independent (Unit 2); Initial Fuel Load Witnessing (Unit 3); Plant Trips (Unit 2);

inspection effort.

Test Program Routine, unannounced resident inspection of the Unit 3 Preoperational items; plant including the following areas: follow-up on inspector identified tour; and TMI Action Items. -CEiVED Tnis inspection involved 63 inspector hours on Unit 2 and 47 inspector hours 223 ,

on Unit 3 for a total of 110 hours0.00127 days <br />0.0306 hours <br />1.818783e-4 weeks <br />4.1855e-5 months <br /> by one NRC inspector. U Results: Of the 13 areas examined, one apparent item of noncomspliance was identified 4).

TMMure to properly administer operator overtime - paragraph 11, severity level RV Form 219 (2)

DETAIL S 1.Persons Contacted

• H. Ray, Station Manager

• B.Katz, Technical Manager

• H.Morgan, Operations Manager P. Knapp, Health Physics Manager

• J.Wambold, Maintenance Manager M. Short, Project Support Manager

• d.. Moody, Deputy Station manager

• P.Croy, Compliance and Configuration Manager A. Talley, Material and Administrative Services Manager

• F. Eller, Security Manager D. McCloskey, Emergency Preparedness Manager

• D.. Schone, Units 2/3 Project Quality Assurance Supervisor

• P.King, Units 2/3 Operations Quality Assurance Super-iisor

• C.Horton, Units 2/3 Startup Quality Assurance Supervisor

• C. Kergis, Lead Quality Assurance Engineer, Unit 3

• V.Fischer, Superintendent of Plant Coordination

'G.Patterson, Startup Quality Assurance Engineer

• K.O'Conner, Unit 3 Startup Supervisor

• M.Spear, Compliance Engineer The inspectors also interviewed and talked with other licensee empioyees during the course of the inspection; these Included shift supervisors; control room *operators, startup engineers, and quality assurance personnel.

• Denotes those persons attending the exit interviewv on November 19, 1982.

Also present at the ex~it interview were M. Mendonca, Reactor Inspector and P. Stewart, Reactor Inspector..

2. Follow-up on Inspector Identified Problems (Units 2 and 3)

A. (Closed) (82-30-02) Use of out of date annunciator procedures in the Control Room The Inspector previously found that eight of twenty three (non-controlled pink) annunciator procedures were several months out of date. These uncontrolled procedures apparently were for operator use inthat they were located on the control room panels In front of the applicable annunciator panel. The licensee inresponse to this situation removed the pink copies and installed controlled white copies. Thus, adequate document control appears to have been effected. The inspector did not observe any negative safety impact resulting from the existence of the out-of-date-procedures. No items of noncompliance or deviations

• were noted.

3. Ocerational Safety Verificatfon (Units 2 and 3)

The inspector observed control rocm operations, reviewed apolic3bie logs and Interviewed control room operators during the inspection period. The inspector verified the operability of selected erergency systes, reviewed tagout records and verified proper return to service of affected comoonents.

Tours of Unit 3 (contairent, safety equipment building, diesel generatzr building and turbine building) the common control building and radwaste building and the Unit 2 turbine building were conducted to aoserve plant equipment conditions. The tours were conducted to inspect for potential fire hazards, fluid leaks, and excessive vibrations and to verify that maintenance requests had been initiated for equipment in need of maintenance. The Inspector, by observation and direct interview, verified that selected positions of the physical security plan was being implemented in ac:ordance with the station security plan.

The inspector observed plant hcusekeeping/cieanliness conaitions and verified implementation of radiation protection controls. These reviews and observations

• were conducted to verify that facility operations were in conformance with the requirements established under technical specifications, 10 CIR, ano administrative procedures..

SNoitems of noncompliance or deviations -*ere identified.

4. Monthly Surveiflance Observation (Units 2 and 3)

SThe.nspector observed a surveillance required by technical specificaticns (Core Operating Limit Supervisory System is out of service testing) and verified that: testing was performed in accordance with adequate procedures; that test instrumentation was calibrated; that limiting conditions for operation were met; that removal and restoration of the affected components were accm-plished; that test results conformed with technical specification and procedure requirements; test results were reviewed by personnel other than the individual directing the test; and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management personnei.

O*,,.The inspector also witnessed portions of the following test activities:

S023-3.25, Once a shift surveillance, (modes 1-4); and S023-3-3.22 Reactcr Pre-refueling Surveillance. *.K No items of noncomoliance or deviations were identified.

S. Monthly Mainteanr.ce Obser'.etion (Unit 2)

Station maintenance activities of components listed below were observed and/or reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides, industry codes and standards, and in conformance ita technical specifications.

- 'A a -

-3 a) Feed regulating valve 2FV1121 operator repair b) Foxborro 200 power supply plug mounting repair No items of noncompliance or deviations were identified.

6. Review of Plant Operations/Onsite Review Committee (Unit 2)

The inspector examined the onsite review functions conducted during the period of February 16, 1982 to October, 1982 to verify conformance examination with technical specifications and other regulatory requirements. This included: review group membership and qualifications; review group meeting verification that review of certain plant activities, frequency and quorum; and, specification required by technical specifications (including proposed technical and changes, noncompliance items and corrective action, proposed facility procedure changes and proposed tests and experiments conducted per 10 CFR 50.59) was performed.

No items of noncompliance or deviations were identified.

7. Witness of 20% Power Plateau Power Ascension Testing (Unit 2)

The inspectors observed selected portions of the following tests:

NSSS Calorimetric 2ST-244-10 Subchannel Gain Adjustments 2ST-344-i2 on a selected During the performance of these tests, the inspector verified, basis by observation and discussion with licensee.personnel, that those portions of the tests observed were conducted using an approved procedure, and recorded, test equipment was properly calibrated, test data .were. collected and that the test adequately demonstrated conformance with applicable acceptance criteria.

No items of noncompliance or deviations were identified.

8. Witness of Transient Tests (Unit 2)

The inspector observed selected portions of transient test 2PA-401-01 (20.

main control board Rx trip).

a selected During the performance of this test, the inspector verified, on those basis by observation and discussion with licensee personnel, that portions of the test observed were conducted using an approved procedure, test equipment was properly calibrated, test data were collected and recorded, acceptance and that the test adequately demonstrated conformance with applicable criteria.

No items of noncompliance or deviations were identified.

9. Witness of Initial Fuel Load (Unit The inspector observed the licensee's performance of initial fuel loading in accordance with procedure 3FL-101-01. Based on these observations, the inspector established the following:

"a. The licensee appeared to have performed these activities in accordance with regulatory requirements.

b. The nuclear instrumentation required for this procedure appeared to have been properly calibrated and proper operation was demonstrated.

c. Direct comTunication was established between the control rccm and the refueling level.

d. The staffing requirements for this activity appeared to have been met.

e. A current procedure was utilized.

f. Inverse Multiplication Plots were being properly :naintained.

g. The boron concentration appeared to be properly sampled and analyzed.

Overall, this activity appeared to proceed very smoothly witn few problems.

Initial fuel load coimnenced on November 15 and was completed on November 21, 1982.

No items of noncompliance or deviations were identified.

10. Plant Trips (Unit 2)

Following the plant trips on November 10, 11, 13 (two trips) and 17, the inspector a,.*.ertained the status of the reactor and safety systems by observation of control room indicators and discussions with licensee personnel concerning plant parameters, emergency system status and reactor coolant chemistry.

The inspector verified the establishment of proper ca.mmunications and reviewed the corrective actions taken by the licensee.

All systems responded as expected and the plant was subsequently returned to operation. The plant remained in Mode 5, while recovering from out of specification steam generator chemistry, for an extended period following the trip on November 17, 1982.

No items of noncompliance or deviations were identified.

-5

11. Indeoendent Inspection (Units 2 and 3)

a. Use and Approval of Ooerator Overtime The inspector reviewed operator working hours on several occasions since the Issuance of the Unit 2 operating licensee on February 16, 1982. The following is a summary of operator working hours since licensing of Unit 2.

Average Operator Licensed Non Hours Per Operators Licensed Month Week SHIFT SCHEDULE Feb. (Data not reviewed)

March 60 hrs. 3 Watch Sections 12 hr. Watches Same April 60 hrs. 12 hr. Watches Same May 60 hrs. 12 hr. Watches Sime June E8 hrs. 12 hr. Watches Sane July E0 hrs. 4 Watch Sections 3 Watch Sections 8 hr. Watches 12 hr. Watches August 48 hrs. 8 hr. Watches 12 hr. Watches September 48 hrs. 5 Watch Sections 4 Watch Sections 8 hr. Watches 8 hr. Watches October 47 hrs. 8 hr. Watches 8 hr. Watches The inspector has also reviewed during the current and previous inspection implementation of operator overtime for conformance with condition 2.C(19)b (Shift Manning) of Unit 2 License No. NPF-1O. The following is a summary of this review:

OVERTIME GUIDANCE DEVIAIONS OCCURRENCES With Proper Without Proper Documented Documented Management Management MONTH CRITERIA Authorization Authorization Feb. Data not reviewed March Fxceeded 72 hrs..In seven day 32* 97*

period April . . . " " 5 19* 0 May .. " . . 4* 0

. .. aune ' If 1* 0

V.o

"-6 OVRTTME GUIDANCE OEVIATiONS OCC2URRE>*CE S With Proper withcut Pr:per Documented 0ocumented Management Management MONTH CRITERIA Authorization Authcrization July Exceeded 72 hrs. in seven day 6*

period August "" " " o 3 September

• October " "4 " " " 1C* (authorizaticn dccumen'tation not verified)

September 16 hr. shift 0 September 24 hr. in 48 hr. period 2

"*Sorme of these occurrences actually occurred on Unit 3, thus t.e number of events associated with Unit 2 are scmewnat less.

Unit 2 License, NPF-1O, condition 2.C(19)b (Shift Manning) states:

"SCE shall develoo and implement administrative procedures to limit the working hours of individuals of the nuclear power ;1ant operating staff who are responsible for manipulating plant controls or for adjusting on-line systems and equipment affecting plant safety which would have an immiediate impact on public health and safety.

Adequate shift coverage shall be maintained without routine heavy use of overtime. However, in the event that unforeseen problems require substantial amounts of overtime to te used, the following guidelines shall be followed:

1. An individual shall not be permitted to work mcre than 16 hcur3 straight (excluding shift turnover time).

2. An individual shall not be-permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any sever day period (all excluding shift turnover time).

3. A break of at least eight hours shall be allowed between work periods (including shift turnover time).

-7

4. The use of overtime shall be considered on an individual basis and rot for the entire staff on a shift.

Any deviation from the above guidelines shall be authorized by the station manager, his deputy, the operations manager, or higher levels of management, in accordance with established procedures and with documentation of the basis to- granting the deviation.

Controls shall be Included in the procacires such that individual overtime will be reviewed monthly by the station manager or his designee to assure that excessive hours have not been assigned.

Routine deviation from the above guidelines is not authorized."

Previous reviews of operator working hours have resulted in two Notices of Violation (One level IV, on April 23, 198P for the 97* non-approved overtime occurrences in March and one level V on November 8, 1982 for the two occurrences in the July, August time frame). The current review identified three occurrences of non-approved overtime use during the September time frame. These occurrences are categorized as a level 1V violation. The most recent occurrence of non-acproved overtime use appears to have resulted from the following failures in the licensee's tracking system.

(G) The licensee's system for keeping track of operator hours relied upon scheduled hours rather than hours actually worked. Since operators sometimes work longer than scheduled, actual hours worked were apparently not identified to management. This resulted in three cases where overtime deviations occurred without aoprooriate management approval. This condition was corrected on :111/82 by Special Order 82-38.

(2) The licensee's program also appears inadequate in the implementation of the overtime guidance criterion of not exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period. This was due, in part, to the licensee's reviewing of only calendar day periods rather than any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period.

This item was corrected on the interim basis by holding a training session for the overtime reviewers to make them aware of the need to look at any 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period. The licensee is further developing an operations procedure to consolidate and formalize the operations department overtime control program. This procedure will be published by January 3, 1983. (50-361/82-39-01)

b. Temporary 14odification Log The Inspector raviewed the Lic"nsae's Temporary Modification Log for conformance to- the licensee's operating instruction S023-0-16 (Temporary Modification Control), revision 4, dated 7/13/82, and American National Standard N18.7-1976. The following discrepancies were identified during a review of 115 temporary nodifications forms (TMFs) contained in the control rocm tempcrary modification logs.

-8 (1) Fifteen TMFs were missing the "requesting department supervisor" review signature and dates.

(2) Twenty-five of fifty-eight TMFs checked did not have applicable caution tags affixed in -he control room to alert the operator to the existence of the temporary modification.

(3} Eight TAFs did not have the nonconformance report conditional release status annotated when the equipment was declared operable.

(4) Two TMFs were still open but the modification had been removed.

These were both on non-safety related equipment.

(5) Fourteen TMFs idcntified instances where systems appeared to be returned to service, but the TMs did not reflect that they had been declared operable by the operator.

The fact that many of the above discrepancies are covered by other tracking systems (such as the Equipment Control and Nonconformance Reporting) mitigates the safety significance of this finding. The inspector considers that the lac: of caution tags in the control room is of safety significance because it reduces the operators ability to maintain awareness of temporary modification status.

The licensee's Quality Assurance organization has initiated initially a daily check of new temporary modification forms versus caution tags being hung in the control room beginning 11/22/82.

The Station Operations Manager stated that the Temporary Modification instruction S023-0-16 would be revised as necessary in light of the above findings and the necessary additional manpower would be expended to upgrade the condition of the temporary modification log. The licensee committed to complete the above actions prior to January 20, 1983.

(50-361/82-39-02)

No items of noncompliance or deviations were identified in this area.

12. Follow-up on Insoector Identified Items The inspector examined the status of the licensee's program to maintain environmental qualification of safety equipment considering the licensee's August 23, 1982 letter to NRR and the August 30, 1982 letter from NRR to the licensee. Based on discussions with licensee personnel, it appears that the licensee understands the requirements in this area and sufficient work has been done to assure the coni.inued development and implementation of the environmental qualification naintenance program within the time frame specified in the August 30, 1982 letter from NRR to SCE. This item is closed.

No items of noncompliance or deviations were identified.

-9

13. P~ant Tour The inspector toured Unit 3 and found that plant housekeeping was adequate for fuel load. The Inspector found that fire protection equipment was being upgraded in preparation for fuel load and that, emergency lighting installation and testing was essentially ccmplete, The inspector also spot-hnecked the adequacy of various testing activities in progress. No items of noncm*npliance or deviations were identified.

14. TMI Action Itens:

a. (Closed) I1.F.2 - Instrumentation for Detect'on of Inadecuate Core coolinga Based on discussions with licensee personnel and visual inspection and demonstration of the equipment Involved, the inspector verified that the licensee had completed action to assure that:

(1) The subcooling monitors were modified to include the maximum unheated junction thermocouple temperature and the representative core exit thermocouple input.

(2) Incore detector assemblies (core exit thermocouples and associated cabling) are environmentally qualified and have seismic and environmentally qualified Class IE connectors.

(3) Qualified cables were installed for the core exit thermocouples.

(4) The heated junction thermocouple probe and associated process instrumentation were installed.

No items of noncompliance or deviations were identified.

b. (Closed) Item I.D.1 - Control Room Design Review The inspector verified, by visual inspectic; s, 2-d d

• with licensee personnel, that the following lt.-is #ere sa ~t.ri1 cmpaed prior to fuel load.

(1) Primary makeup pump flow controller labeling errors were corrected.

(2) Technical specifications red arrow placement errors were corrected.

(3) Safety Injection pattern recognition drawings were approved and placed In the control room.

(4) Operator training on Unit 3 plant computer was satisfactory.

-10 (5) HVAC panel SLI1S5 open/closed legend inconsistencies were corrected.

No items of noncompliance or deviations were identified.

c. plosed Item I.C.6 - Verification of Correct Performance of Qoeratinq Activities The inspector verified that all systems required to support fuel load were turned over to the operations staff before fuel load commenced and that the I.C.6 program initiated on Unit 2 had been implemented on Unit 3.

No items of noncompliance or deviations were identified.

15. Exit Interview - Units 2 and 3 The inspector met with licensee representatives (denoted in Paragraph 1) on November 19, 1982 and summarized the scope and results of the inspection.

The licensee acknowledged the apparent violation of license conditions regarding the use and approval of operating personnel overtime (paragraph 11.a).

REFERENCE A MI~M UMTOYcMMIN O Docket No. 50-361' Southern California Edison Company P. 0. Box 800 2244 Walnut Grove Avenue Rosemead, California, 91770 Engineering Attention: Dr. L. T. Papay, Vice President Advanced Gentlemen:

Subject:

NRC Inspection of San Onofre Unit 2 and conducted by Messrs. 1. Cllis This refers to the routine inspection 25 - 29, 1982 of activities F. A. Wenslawski of this office cn January CPPR-97, and to the discussions of Construction Permit No.

authorized by NRC Mr. H. B. Ray and other i ers of yourfindi.ngs our the by staff at held conclusion of with Mr. CIllts the inspection. This also refers to 5 and 8, a meting held in the followup telephone calls on February 4, staff and consultants on February 8 Region V office with members of the SCE 9-12, V office during the period of February and followup reviews in the Region 1982.

are described in the enclosed inspection Areas examined during this inspection consisted of selective exami nations report. Within these areas, the inspection interviews with personnel and of procedures and representative records, observations by the inspectors.

were identified within the No items of noncompliance with NRC requirements scope of this inspection.

of this letter and the enclosure In accordance with 10 CFR 2.790(a), a copy Room unless you notify this office, will be placed In the NRC Public Document of this letter and submit written by telephone, within ten days of the date therein within thirty days of application to withhold information contained must be consistent with the the date of this letter. Such application requirements of 2.790(b)(1).

inspection, we will be glad to Should you have any questions concerning this discuss them with you.

Sincerely, H. E. Book, Chief

'Radiological Safety Branch

Southern California Edison Co any -2

Enclosure:

Inspection Report No. 50-361/82-09 I:

1. 1 U. S. IWCL*,A REGULATORY COMMISSION 4:

Report No. 50-361/82-09 7

-4 Oocket No. 50-361 License No. CPPR-97 I -

Licensee: Southern California Eidson Co any P. 0. Box '

2244 WAlnut Grove Avenue RosDmad, California 91770 Facility Name: San Onofre Unit 2 Inspection at: San Onofre Site, San Die*o County, California Inspection Conducted: January 25 - February 12, 1982 Inspectors: MI. Ctllts, Radiation Speialist FF. k. Me-nslawskl, Whtef, Reactor Radiatro-n Approved by:

Date Signed Prtetion Sectiton' f

op3-Approved by: W., E. Book. Chief," Radilog'_ic'al" Safety Branch .712-149 Date.Signed Inspection Summary m1 Inspection on January 25-February 1i,1982 (Report No. 50-361/82-09)

Areas Inspected: Routine announced preoperational inspection which included a tour of facilities, action on IE Circulars, and an examination of licensee action on previous inspection findinqs in regards to the status process and effluent radiation monitoring systms and the radiological envtloinmental monitoring program prior to the issuance of an Operating License (O.L.)* The inspection involved 71 hours8.217593e-4 days <br />0.0197 hours <br />1.173942e-4 weeks <br />2.70155e-5 months <br /> of on site time and 79 hours9.143519e-4 days <br />0.0219 hours <br />1.306217e-4 weeks <br />3.00595e-5 months <br /> of followup inspection effort at the Regional Office by two NRC inspectors.

Results: No items of noncompliance or deviations were Identified. Agreements were reached by SCE, NRR (ETSB) and the NRC Regional office for implemntation of the lIcensee's process and effluent monitoring systems, radiological envitomental monitoring program and a Quality Assurance program for effluent and~enviromental wmni tor ing to support issuance of an operating license for the facility.

M23292§0_R9Q222 F

DETAILS L 1. Persons Contacted Southern California Edison Coany (SCE)

• H. B. Ray, station "614"er Deputy Stati on ICoody, 3Ifnage

• +0. ENunn, Project Maager T. Elkins. Startup Engineer

• T. Garvens, Lead Quality Assurance E*gineer

'8. Katz, Stition Technical ManaerIX

• J. P. Albers, Health Physics Engineer

• W. C. Marsh, Health Physics Manager (Acting)

• C. A. Kergis, Operations, Quality'Assurance Engineer D. Pilmer, Manager, Nuclear Engineering and Safety

• +D. B. Schone, Project QA Supervisor, Units 2/3

• +R. Rosenblum , Supervisor, Construction &.T/S Er,.ineerin.

W. G. Frick, Chemistry Supervisor

• F. Briggs, Compliance Engineer

• P. King, QA Supervisor, Operations K. Slagle, Startup Engineer G. Holloway, Supervisor, Startuo Engineer

÷R. DiOetch, Vice President, Nucelar Engineering & Operations

+J. G. Haynes, M*nager nuclear Operations

+G. Morgan. Station Manager, Operations

+*. Medford, Manager, Songs 213 Licensing Bechtel Power Corooration

• *+J. R. Purucker, Professional Engineer

• S. H. Fried, Professional Engineer O. Hansen, Professional Engineer, Senior MNo er Allen Nuclear Associates., Inc. (ANA, Inc)

• L. Reynolds, Radiation Protection Engineer

.÷V. 0. Allen, Radiation Protection Enaineer

• Denotes those present at exit interview held on January 29, 1982.

• Denotes those Present at meeting held at Region V Office on February 8, 1982.

In addition to the Individuals noted above, the inspectors held conference calls with SCE and NIRR (ETSB, RAS) personnel on February 4, 5, and 8, 1982 and met with an? interviewed other Pmui'ers of the licensee's and contractcrs staff at the site and .'t the NRC Regional Office on February 8,..1982.

-2

2. General Discussion The purpose for the Inspection was to exmine SCE's capabilities and readiness for. imlamentatton of a radiation protection program that is consistent with the Technical Specifications (TS.) prior to issuance of an Operating License (O(L.). The focis of the Inspection was concentrated on the status of:.

a. Implenentation of Process and Effluent Monitoring Systems and procedures and training governing these system.

b. Implementation. of a Radiological Enviromental Monitoring Program required by Section 3/4.12 of the T.S.

c. Implementation of an approved Off Site Dose Calculation Manual (ooCM) required by Section 6.14 of the T.S.

d. Implementation of an approved Process Control Program required by Section 6.13 of the T.S.

e. implementation of a Quality Assurance Program-for effluent and environmental monitoring using the guidance in Regulatory Guide 4.15, Revision 1, February 1979 as. required by Section 5.8.1.1 of the T.S.

Previous NRC concerns in regards to the above items are discussed in Region V, IE Inspection Report 50-361/81-35 and previous Region V preoperational inspection reports.

The site inspection, ending on January 29, 1982. included an examination of procedures, records, and discussions with the licensee's staff and NRR (ETSB and RAS) personnel. Also included was a tour of the licensee's facilities at Unit2. Process and effluent monitoring systems located in' the rad waste, containment and auxiliary buildings were observed during the tour.

Insiection findings revealed that the licensee was not fully Prepared to implement his program with respect to items a through e above consistent with the T.S.'s unless the concept for a phase-In-approach discussed in paragraph 2 of Inspection Report 50-361/81-35 was approved by the NRC.

The NRC inspectors concluded that the phase-in-approach concept could be safely iýplemented provided the O.L. and T.S. were amended to clearly.

define specific conditions for implementation of certain Items. This conclusion was based on:

"* tI

-3 Discussions with the licensee staff and SCE mnagmept at the January 29, 1982 exit interview. at"

. An examination of SCE correspondence provided to the NRC Region V office and NRR between the period of February 1-12, 1982.

Conference calls between SCE, NRR and NRC Region V Reactor Radiation Protection Section on February 4th, Sth and 8th, 1982.

Discussions from a meeting between SCE mnagemet personnel 4.

denoted in paragraph 1 and the RC staff at the Region V office on February 8, 1982.

Conference calls between NRC, Region V and NRR (ETS3 and RAS)  :'r between February 1 and 12. 1982.

All of the correspondence provided by SCE satisfactorily addressed NRC findings discussed at the January 29. 1982 exit interview and will be included*as Enclosures 1 through 5 of this report.'

Subsequently the T.S. 'and D.L. were modified to the satisfaction of SCE, NRR (ETSB. and RAB) and NRC Region V staff. These modifications clearly define the conditions for implementation of items a -chrough e above using the-phase-in-approach concept.

With a few exceptions, the conditions established in-the O.L. and T.S. as a result of this inspection will require the licensee to fully imlement items a throtigh e above prior to first exceeding 5%rated thermal power or sooner. The exceptions are'as follows:

a. An enhanced system for continuous monit~kfio asid samling of the containment purge exhaust directly from the pprge stack shall be

.installed and operational prior to startup folown the first refueling outage. In the interim, the c*ftinment airborne monitor ZRT-7804-l and associated sampling media shall nerfors this function.

b. Continuous samp ing (T.S. Table 4.11-1, Notation C) provisions shall be operational 'prior to January 1, 1983. In the interim, administrative controls for composite samoling of continuous releases per T.S. Table 4.11-1, Table Notation. b. will be allowed.

c. Sampling of the Miscellaneous Waste Evaporator Condensate will not. be required if the Condensate Monitor Tank Bypass Valve (SA141S-2 1/2"-200) is verified locked closed at least once per 31 days.

-4 Remaining cnoditions, for the most part are identified in Section 3/4.10.5, "Special Test Exceotions', the O.L. or In the applicable portions of Appendix "A"to the T.S.

Details somriZing the above are discussed in the subsequent sections of this report.

NO items of noncomliance or deviations were identified.

3. Technical Specifications Surveillance Requirements A review of Sti.tion Order S023-G-3, Revision 2, "Technical Specification Surveillance Requirments" was conducted during the Inspection. The purpose for the Station Order Is to outline the surveillance reauirements of the T, S. and to define the responsibilities and identify the appl cable procedure " 7 for accomplishing the T.S. surveillances.

The inspection revealed that approximately 50% of the .health physics' related procedures listed in the station order were not yet issued at the time of this inspection. The insoection also revealed that some of the -.

procedures were orepared prior to the issuance of the latest T.S. revision and .were probably obsolete and/or outdated. Most of the procedures oertaininq to process and effluent monitoring systems were not issued.

Discussions with the licensee's staff at the exit interview indicated that the Task* Force (discussed in paragraph 9 of IE Inspection Reoort 50-631/81-35) would be responsible for issuing these procedures. The schedule for issuing these" procedures had been established to support the implementation of the involved monitoring system using the phased-in approach concept. A schedule for preparation and issuing of these procedures was provided to the Inspector. The schedule appeared acceptable.

The inspectors examined Chemical Procedure 5023-111-1.6, Revision 2.

"Primary System Chemical Limits", dated 1 April 1981 during the inspection. This procedure was one of those listed In Station Order S023-G-3. The review of this procetiure revealed an error existed in paragraph 6.1.4. The Dose Equivalent Iodine-131 value less than

<C6.5 millicurles per gram snecifted in this .aragraph is of not in agreement with Section 3/4.4.7 of the T.S. which requires the specific activity of the primary coolant be limited to less than :S1.0

• microcuries per gram Dose Equivalent Iodine-131. This was discussed at the exit interview.

The Inspectors reviewed the procedure for and test results of the "Generic Tests" (G.T.) of the Unit 2 MNC Contaisment Airborne Radiation Monitoring System. The G.T. consists of 10 individual modules for performqig calibration and functional checks th*t were consistent with the FSAR renuirevtents. The neneric tests checked such items as:

I

g

-- 5

. digital output circuit calibrations/functional verifications Pt

. power supply Ai

• modular count rate meter

. filter paper advance and check source drive circuits

. flow instrumentation Additionally, instrument and control loop verifications and isotopic standarizations were performed with this test procedure. The isotopic 4 tests were performed on all three system channels (gaseous, particulate .V and iodine) using NBS traceable sources. The tests were performed in accordance with Section 11.5.2.1.5.2 of the FSAR using generally accepted methods and procedures croon to industry practice.

The licensee Task Force members (discussed in paragraph 9 of the IE Inspection Report 50-361/81-35) stated that the calibration of the Containment Airborne Radiation Monitoring System (as well as other process....

and effluent monitoring systems) did not meet the requirements of TABLE NOTATION (2) of Table 4.3-8 of the T.S. and the requirements of R.G. -4.15', Revison 1. Table 4.3-8 requires the initial channel calibration of the monitoring system over its intended range of energy and measurement range. Regulatory Guide 4.15, Revision I requires an enhanced calibration and quality assurance program.

New calibration procedures are being developed by SCE's Radiation 'h Monitoring Task Force to perform an "enhanced calibration* that will be consistent with the T.S. and Regulatory Guide 4.15, Revision 1. The

.*enhanced calibration" for process and effluent monitoring systems will be implemented using the phased approach. In the interim the data of

.initial vendoAs calibration and system calibration. performed on-site have been reviewed by qualified professionals and been determined to be adequate'and consistent with the calibration requirements of the FSAR.

The NRC inspector was in agreement with this approach after discussions

.with SCE and NRR (ETSB & RAB) and reviewing the SCE correspondence discussed in Section 2 of this report.

The O.L. and Appendix *Am of the T.S.; in particular Section 3/4.10.5 of the T.S., were modified to clearly define the conditions associated with the implementation of the process and effluent monitoring systems using the phase in approach.

No items of noncompliance or deviations were identified.

5:..

-6

4. TM! Action Items The inspectors examined the lice'see status for implementation of certain ThI Action Plan Requirements discussed in MREG 0737, Items 1I.B.3 .

and II.F.1 and paragraph 6 of IE Inspection Report 50-361/81-35. The inspection report identified that the licensee would formally request NRR approval to extend the completion of these items. 'The inspectors examined: (a) a licensee's memorandum to IFRR dated Decmber 22, 1981, (b) SER, Supplement 4, and (c) conditions which were added to the O.L.

The examiniatlon revealed that the approval for implementation of these items has been extended to prior to first exceeding 5% rated thermal power. Additionally, a similar approval for extended itqlementation of Sections 6.8.4.b, "In-plant Radiation Monitoring" programs and 6.8.4.d. "Post-Accident Sampll.ng" program was granted. The conditions for implementation of the above items are clearly defined in the O.L. and Appendix WAto the Technical Specifications. The need for these extensions were discussed at the exit Interview.

No items of noncompliance or deviations were identified.

5. Radiological Enviromental Monitoring Program (REMP)

A meeting was held with SCE management on January 26, 1982 to discuss the implementation of-a REMP that will be consistent with Sections 3/4.12 and 6.8.1.1 of the T.S.. Also discussed where the concerns with the REMP identified in paragraph 5 of IE Inspection Report 50-361/81-35.

The discussions revealed that the licensee had prepared an action plan for upgrading the REMP at Units 2/3 to ensure compliance with the T.S. requirements. The plan also provides for a systematic upgrading of the REMP currently in effect at Unit 1. An SCE corporate office group has been designated the responsibility for implerentation of the REMP.

Implementation of a REMP that will be in full comoliance with the T.S. is not expected to be completed until prior to first exceeding 51 rated thermal power or July 1, 1982, which ever coams earlier.

SCE has submitted a formal request to NRR and HRC's Region V Office asking for relief for implementation of the Interlaboratory Comparison program specified in Section 3/4.12.3 and for imolementation of the Quality Assurance Program soecified in Section 6.8.1.1 of the T.S..

The request was reviewed and deemed acceptable by NRR (ETS8 and RAW) and the NRC Region V staff. Specific condi-tions authorizing the refief have been clearly defined in the O.L. and Appendix "A" of the T.S..

No items of noncompliance or deviations were identified.

-7

6. Impl'entation of Process and Effluent lonitorino Systems The Inspectors conducted a tour of the Unit 2 facility for the purpose of observing the status of process and effluent monitoring systems.

Concertis that could affect the implementation of process and effluent monitoring systeas consistent with the T.S. which were identified from previous Inspections and this tour were discussed with the licensee.- ....41 The concerns were discussed in detail with the Task Force and at the exit interview. Also discussed were items that Interfaced with the implementation of process and effluent monitoring systems. The need for obtaining satisfactorily resolutions for each concern and/or item identified. prior to issuance of an 0L was stressed during the discussions.

The following concerns/Items were discussed:

a. The environmental qualification of the Contaiment Area- High Range Monitors.

b. The ability of the NK and GA monitoring systems to meet ANSI-N13.1, "Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities", due to the long samollnta lines and nmerous r qht angle bends and mechanical fittinos on the sampling skids.

c. Whether particle deposition and heat tracing engineering evaluations were accomlished for all of the process and effluent wonitorina systems.

d. Schedules for completion of SA1particle deoosition. studies.

e. The necessity to h*at trace the ?Ik Plant Vent Stack Airborne Monitor had not been resolved.

f. Whether the Unit I condensation problem associated with the GA wide range monitor was also anplicable to Unit 2/3 GA ranitoring systems.

The condensation problem with the Unit I wide range monitor was reported to Region V by the licensee. The reoort identified that the problem existed even thouqh the sampling lines were heat traced.

g. The acceptability of the Containment Airborne Monitor to met the T.S., Table 3.3-13 reouirement for monitorinq the contai*l ent purge.

h. The me'*od for accomolishinr continuous sz.-oling of the containment Purge, plant and vent condenser evacuation system as required by the T.S..

i. Information regarding the acceptability of the orocess and effluent monitoring system initial calibration and the method and schedule for accompl.ishing the enhanced calibrations.

j. Preparation and issuance of procedures for perfoming T.S.

channel calibrations, channel functional checks, source checks and other T.S. surveillances.

k) Training of personnel in the use of and requirements for process and effluent monitoring systems and the Radioactive Effluent Monitoring Program.

The above concerns were also discussed with NRR (ETSB and RAS) personnel as identified in Section 2 of this report. Additionally, the licensee had provided the URC with the correspondence (Enclosures I through 5) discussed in Soction 2 of this report. The discussions and correspondence satisfactorily addressed the above concerns and as a result the O.L. and T.S. were subsequently modified as discussed in Section 2 of this report.

Concerns not included as conditions in the O.L. and T.S. were resolved by discussions and in the licensee's correspondence provided to the inspectors.

No items of noncompliance or deviations were identified.

7. Radiological Effluent Monitoring Progm The inspectors reviewed Chemical Procedure S0123-II1-5.0, Revis-ion 0, "Effluent Monitoring Proram" and met with. the effluent engineer discussed in Section 3 of IE inspection Report 50.361/81-35.

Procedure S0123-111-5.0 defines the Radioactive Effluent Monitoring Program. The program has been assigned to the Supervisor of Plant Chemistry for establishing procedures for monitoring, sampl tog and analysis and record keeping required for liquid and airborne radioactive waste releases. The effluent engineer has been assigned the responsibility for implementation of the Effluent Monitoring program.

Discussions were held with the Effluent Engineer and a review of a schedule he i'ad Prepared for imolementatlon of the Effluent Monitoring Program was conducted. The discussions revealed that the scheduled Implementation of the program was well defined. - Implementing procedures and training were expected to be complete by February 19. 1982.

The establishment of this program appeared to be emerging in an orderly.

process due to the efforts of the effluent engineer.

No items of noncompliance or deviations were identified.

8. Licensee Action on IE Circulars

a. 'EC 81-09. Containment Effluent Water that Bnasses Radioactivity Monitor.

The licensee's evaluation adequately addressed the concerns rof the circular. The evaluation concluded that all possible liquid effluent release paths were being monitored. This matter is considered

.closed. (IC-81-09).

-9

9. Licensee Actions on Previous Inspection Findinqs A question raised in paragraph 8 of IE Inspection Report 50-361/81-35 concerning the possible leakage of Quick Disconnects (Q.D.'s) associated with the NMC Plant Vent Stack Monitor was evaluated by the licensee.

The inspector examined the licensee's evaluation report. The report identified that the type of Q.D. used has a proven performance record and of greater siqnificance is the fact that the Q.D. location is on the negative side of the pumo so that any failures causing leakage would be inward. The licensee was informed that the evaluation adequately addressed the question which was raised.

No items of noncompliance or deviations were identified.

Ia. Exit Interview The inspectors met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the site inspection on January 29, 1982.

The inspectors summarized the scooe and findings of the inspection.. The licensee was informed that there were no apparent items of noncompliance or deviations. The inspectors discussed the concerns summerized in Sections 2, 3, 4, 5, 6 and 7 of this report. The inspectors conmmended the efforts of the Effluent Engineer. Strong management effort was ccvnittei,, ..

in response to resolving the concerns identified by the inspectors.

At the licensee's request, a management meeting was held in Region V office on February 8, 1982 to discuss the pronress.and status of open items impending before the issuance of the operating licens_.

I DEZICGAZD C21G:i:9L Certified By Southern California Edison Company -"

SAM 0-.OUt NfUCLErAN GQCNMA-TfY4G STATIOM P.O. BOx ~s.

$APO ctcm.emyg. &AO4* *4,

3. M.

RAY

%,A,,o.-.*=AGt. February 1, 1982 U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region V 1450 Maria Lane, Suite 210

.Walnut Creek, California 94596 Attention: Mr. Frank Wenslawski

Subject:

Information Committed to be Provided Region V as a Result of January 29, 1982 Exit Interview by Messrs.

Wenslawski and Cillis During the subject Exit Interview concerning the Region's pr.operational inspection of the Health Physics inspection modules for San Onofre Unit.2 fuel loading, we enumerated ten specific items of information which would be provided the Region for review. In addition, we committed to provide the Region with a copy of the Technical Specifications related to process and effluent monitors, as marked up at the January 23, 1982 meeting with representatives of the Office of Nuclear Reactor Regulation.

Enclosure (1) to this letter identifies the-status of each of the ten specific items enumerated at the January 29, 1982 Exit Interview. 'That status reflects the fact that four of the ten items are provided as Enclosures (2), (3), (6) and (7) to this letter; another item is partially provided by Enclosures (4) and (5) to this letter; and all remaining items will be provided by February 5, 1982. Information provided as enclosures to this letter includes all items ident;ified by Messrs. Wenslawski and Cillis as necessary to permit favorable input (in the areas of their inspection) by the Region to the Office of Nuclear Reactor Regulation regarding our preparedness for fuel loading at Unit 2, with the exception of item 8.. (training), which will be prgpvided by February 4, 1982.

~J PDR I

U. S. Nuclear t Regulatory Commission Februa Lry 1, 19B2 with respect to the forwarding of a copy of the marked-up Technical Specifications related to process and effluent monitors, that will be received by you under separate cover on February 2, 1982..

If you have any questions concerning the information forwarded by this letter, or require additional information, please let me know.

Enclosure (1) 9.

INFORMATION COMMITTED TO BE PROVIDED i REGION V AS A RESULT OF JANUARY 29, 1982 EXIT INTERVIE BY MESSRS. WENSLAWSKI AND CILLIS ITEM STATUS

1. Provide Region V Wit7. a copy of To be provided by correspondence with NRR requesting relief February 3, 1982 from T. S. 6..8.1.i for implementation of QA in Radiological Environmental Monitoring Program until 5% power or 7/1/82, whichever comes first.

To be provided by

2. Provide Region V with a writeup repre senting a systematic evaluation of sampling February 5, 1982 line compliance with ANSI 13.1 and other, applicible criteria (include discussion of intended use of SAI, heat tracing and condensation considerations).

• 3. Provide Region V with a writeup present Enclosure (2) ing our position with respect to how we will meet tech spec requirements for continuous sampling of containment purge, etc; include a schedule.

• 4. Provide Region V with environmental Enclosure (3) qualification documentation for containment area high-range monitor cabling and connection (confirm acceptable environment al qualification of entire system; however, no additional submittal of information to the Region is required).

'5. Provide Region V with a writeup Enclosure (4) describing system calibration addressing: provides information (1) why vendor calibration is satisfactory for four monitors and has not been subsequently affected; and, (Control Room (2) the origin and acceptability of field Airborne; Contain calibration sources. ment Airborne; Con tainment & Purge Area; and, Plant Vent Stack.Airborne Monitors). Informa tion for additional five monitors (Hi range in Containment; Radwaste Discharge Line; Blowdowr Neutralization Sump; Turbine Bldg. Sump; and, Steam Jet Air Ejector Monitors) to be provided February 4, 1982. Enclosure Must be addressed insofar as the (5) provides the basi five monitors required for* fuel for the schedule for loadin9 in order to permit favorable input calibration of these bv Recion V to NRR ronaraina fr~Anrt~q nine monitors.

I

% Enclosure d)

ITEM

• 6.

Provide Region V with a schedule for the completion of all Task Force procedures.

7. Incorporate alarm set points, 2

STATUS Enclosure (6)

To be provided I

calibration curves and other information February 3, 1982 in the ODCM, or justify their exclusion. Provide Region V with a schedule of our plans in this regard.

"*8. Provide Region V with a schedule for To be provided completion of training in the use of by February 4, 1982 process and effluent monitoring system.

9. Provide Region V with a summary of Enclosure (7) enhanced calibration which will be undertaken to ensure conformance to the tech specs; include a schedule.

10. Provide Region V with a writeup To be provided concerning the implementation of a QA by February 4, 1982 program for effluent monitoring, as required by Tech Spec 6.8.1.1.

L t.

NW Item 3 - GASD EMIO STMM SAMLD I. CtN!AI9I*T PMZ S MPLD PMESr PIRVISIQM:

edundant NMC gaseous radiation monitors PE-7804-1 and MZ-7807-2 (FS l.5.2.l.4.5) zpresently mitor containment airbotme activity.

One monitor samples the contaiment atasphere at ap ay elevation 90" (sam vicinity as the pzge exhaust) and the other monitor samples at q;rzinately elevation 35". Extensive mixing of the containment atmcbsere by the rxwmal WV1AC units enures that the sample locations are representative of the entire cntain merit atmosphere, and are therefore considered to be repremetativ.

of the containment purge effluent stream. These monitors provide the capability fur Iodine, particulate and gas grab sampling.

At present the particulate sample is of the moving filter paper type. The movint filter paper will be disabled (or alternatively a fixed filter mechani will be installed) to provide interim fixed particulate saiple capabilites per Technical Specification table 4.11-2.B. A correction factor will be applied to saimle

-analysis to accont for sample line deposition. 7his topic will be discussed as part of NRC Item 2. Sample flow indication is provided on the monitor. Based on the above, these monitors will r"

be used to obtain omposite samples of the purge stream as required by Technical Specifications until the emhancemets are complete.

Future Enhancement er 92e capability to obtain- mtinuois, ccmeite particulate and iodine samples directly fzio the purge stack will be provided.

Pae2 ?A Itm3 Future Fjtancmet (Cmt d),

The system will be caple of obtaining repro tavle sames over the full rmqe of cr tairsent pwge opertion. ** systm will also provi,. ga grab saple cabilties, indicatim on Pzr'e flow, 44 samle flow. CoxcepbAl design of this syute has bequm. rn the aence of confimed pimurmrit, WaviWein adi costruction 9dhasiules, operail1ity of thes xciificatiom cannot be acmmitted to prior to 1-1-83. Mon accwA, operbil1ty dates will be available within 90 days.

TI CCN NSV EST.

1he condenser evacuation system Is monitored by to deecto*r systems. First mc mnitor FE-7818 (FS 11.5.2.1.4.17) which is a noble gas monitor. Secondly by General Atomic monitor TE-7870-1 (PSAR 11.5.2.1.4.8) a wide Lad gas moitor which emmelops the Lange of the WC no~ble gas sionitor aid &I=u peavides the capability for IodIine and fixed particulate 6aimtn. Itoe General Atcmc umitor pro*ides effluent flow indication. this capability will be wavlable at Initial Criticality as specfied in the pending ,X-dmcal specif ication revision tble 4.11-2 (double te.rck footnote). The onitors described

• will be used to s1ly csite sawles of the -dou-r ovalu*tion purge stream as r ired by Tedudcal pecificatioms until the the aimmmens are cowlete.

Future Mrtcaent Gas qrab sampling c bilit tes we being ad to the wide range ga moiltor (7870-1).

Muure Owomoswt (Comt'd) and axmst ~~io am now being pxwmas. Mn the

• tome of ~

firme pmcuwin*o ftqgimrirq* aid castruction 9d~dn operability em~ be ccittAid to prior to 1-1-83. Nxe accu.rate comil, 1dates will bet ava~iabl within 90 days.

III PLP~r vWn 9!CK Pfesent Provisions:

PC radiation umnitior M47M0 (TSR 11.5.2.1.4.6) pcowides C~tinixxu mWnitoring of the plat vent stacks a wall as iodine, particulate anid grab ample Wav'isiwns. fteet~ly thia pticulate samle in of the sovini filter papR type. iThe movinq filter pqmwrilil be disabled (cc alterrAtively a fix.

filter. mchanism will he installed) to provide Interin fixed particulate ample cpi~lties per advilcal Specification table 4.11-2.C.2. A correction factor ha beI detecoined for ampl1e line deposition and will he applied to the sampe analysis.

ibis topic will be diaoumsed as part of MW Itas 2. The vemitor also PCOVie total samle flow indiication. This xonitor will he utilized to suply the copsite saipes reuaired by Technical Specif ications until the O~encaimen*.ace ampqlete.

Gereral Atomic wide rae gas acnitcrs (2Wo-7865-I aid 3W-7865,-2, rimR 11.5.2.1.4.9) tvaidi envlops the gassms rauj of in-780S will be available prior to em acing 5%Power (per fTduifrax Specif ication table 3.3-10 dottle asteridc footnote) .*

General Atomicý amitocs Pvide the capailtity for Iodine and fixed pct ictilate sampIng.

REFERENCE B 5' d UWaITED STATES NUCLEAR REGULATORY COMMISSION REGION V 211R SRECEIVED EPI 1450 MARIA LANE. SUITE 210 WALNUT CREEK, CALIFORNIA 945%

MAR 7 1983 NUCLEAR LICENSING March 4, 1983 Docket Nos. 50-206, 50-361, 50-362 Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, California 91770 Attention: Dr. L. T. Papay, Vice President Advanced Engineering Gentlemen: zi.(\ *

Subject:

NRC Inspections - San Onofre Units 1, 2 and 3 This refers to the inspections conducted by Messrs. L. F. Miller and A. E. Chaffee of this office, during the period of January 3 through February 12, 1983, and by Messrs G. P. Yuhas and C. I. Sherman on February 7 through 11, 1983 of activities authorized by NRC License Nos. DPR-13, NPF-10, and NPF-15 and to the discussion of our findings held with Mr. H. B. Ray and other members of your staff at the conclusion of the inspections.

Areas examined during these inspections are described in the enclosed inspection reports. Within these areas, the inspections consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspectors.

Enforcement action related to these inspections will be the subject of separate correspondence.

In accordance with 10 CFR 2.790(a), a copy of this letter and enclosures will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the requirements of 2.790(b)(1).

Southern California Edison Company March 4, 1983 Should you have any questions concerning this inspection, we will be glad to discuss them with you.

Sincerely,

/"!

J" *., s rector D'*sion f Resident, Reactor Projects and Engineering Programs

Enclosures:

A. Inspection Report Nos. 50-206/83-04 50-361/83-06 50-362/83-06 B. Inspection Report No. 50-361/83-08 cc w/enclosures: V R. Dietch, Vice President H. B. Ray, SCE (San Clemente)

U. S. NUCLEAR REGULATORY COMW._,SION REGION V Report No. 50-361/83-08 Docket No. 50-361 License No. NPF-1O Safeguards Group Licensee: Southern California Edison Company P. 0. Box 800, 2244 Walnut Grove Avenue Rosemead, California 91770 Facility Name: San Onofre Unit 2 Inspection at: San Clemente, California Inspection conducted: February 7-11, 1983, and subsequent telephone conversations thru February 25, 1983 Inspectors: G. P. Yuhas *iation Specialist "DatF Signed C.I Shermý" diatlon Spec~ast Datd Signed Approved by F. A. Wenslawski, Chief, Reactor Radiation Protection Dategrigned Section Approved by H. E. Book, Chief, Radiological Safety Branch Date Signed Summary:

Inspection onFebruary 7-11, and subSeguent telephone conversations thru February 25, 1983 (Report No. 50-361/83-08)

Routine uannounced inspection of the implementation of LIcense Condition 2.C.(19)i.

and Technical Specification requirements associated with TMI Action Items (NUREG-0737)

II.B.3 Post Accident Sampling Capability (PASS), II.F.l. Attachment 1, Noble Gas Effluent Monitor, II.F.l. Attachment 2, Sampling and Analysis of Plant Effluents, and II.F.l..Attachment 3, Containment High-range Radiation Monitor. The inspection included review of the as-built systems; evaluation of selected criteria; status of program development; and witnessing of a demonstration of PASS operability.

The inspection involved 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> on site by two regionally based inspectors.

Results: Of the areas inspected, two apparent items of noncompliance were identified (failure to have an operable post-accident sampling system and a fully implemented post-accident sampling program, License Condition 2.C.(19)i, failure to report a violation of a license condition, License Condition 2.G., paragraph 4).

DETAILS

1. Persons Contacted

• H. B. Ray, Station Manager

• W. C. Moody Deputy Station Manager

• B. Katz, Station Technical Manager

• H. E. Morgan, Operations Manager

• P. S. Knapp, Health Physics Manager M. Curran, Manager, Quality Assurance B. Droste, Supervisor, NSSS Schone, Site Quality Assurance Manager

• R. E. Reiss, QA Engineering.

• P. Chang, Effluent Engineer

• R. B. Reardon, QA Engineering

• W. M. Brush, Instrumentation and Control CI&C) Supervisor

• D.

• S.

C. Evans, Emergency Planning W. Chick, Chemistry

• G.

T. Gibson, Technical Compliance

• R. S.

Warnock, Supervisor, Health-Physics Engineering B. Markham, Startup Engineer S. Marlett, Nuclear Engineer

• Indicates those individuals attending the exit interview on February 11, 1983.

In addition to the above individuals, the inspector met with and interviewed other members of the licensee's staff.

2. Licensee Action on PreviousInspection Findings (Open) (82-26-02) Inspector identified item involving control of very high radiation areas. During an October 1982 inspection (Report No. 50-361/82-33), it was noted that a schedule to implement commitments made in the licensee's September 23, 1982 letter had not been established. From discussions with the assigned engineer and review of Proposed Facility Change packages82-355, 82-603, and 82-604, it is clear that a schedule has been established and is being implemented as planned. Completed modifications will be reviewed during a subsequent inspection.

3. II.F.1 Accident-Monitoring Instrumentation This inspection effort was a continuation of the review documented in Report No. 50-361/83-04. During that inspection, indications of a need to improve the operability, maintenance, and administrative controls associated with the radiation monitoring system were observed.

The Supervisor of Instrumentation and Control had become aware of similiar perceptions, such that, at the onset of this inspection he outlined specific actions taken to improve these areas. The actions taken included: (1) Establishment of a task force consisting of an Instrument and Control (I&C) Foreman, I&C Engineer, four station I&C

Technicians, eight I&C Technicians from Action Systems, Inc., and professional assistance from ASTA and Action Systems, Inc. (2) Development of a specialized I&C training program to be presented in March 1983.

(3) A thorough review of the radiation monitoring equipment spare parts situation.

The focus of this inspection effort was to verify compliance with Technical Specification 3.3.3.6, Accident Monitoring Instrumentation, 6.8.4.d. Post-Accident Sampling, and commitments made in the Final Safety Analysis Report (FSAR) and subsequent correspondence.

A. Noble Gas Effluent Monitors There are four pathways by which noble gas could be expected to be released to the environment during accident conditions. The Wide Range Gas Monitor (WRGM) 2RE7865 samples from either the plant vent or containment purge path ways. The WRGM 2RE7870 samples the steam jet air ejector exhaust. The Main Steam Line Monitors, 2RE7874 and 2RE7875, are designed to measure the releases via the main steam pathway.

The inspector found that the WRGMs have been installed as described in the licensee's "Response to NRC Action Plan NUREG 0660, San Onofre 2/3,"

Item II.F.l, and FSAR Chapter 11.5.2.1.1.8. During tours of the facility on February 9 and 10, 1983, with Unit 2 in Mode 1, the inspector noted that the WRGMs were operating consistent with Technical Specification (TS) 3.3.3.6. The WRGM design criteria items A. through H. of paragraph 1.2.1 presented in the licensee's "Response to NRC Action Plan NUREG 0660" were either observed or discussed with licensee representatives. The following observations are noted:

- Calibration of the WRGM low range detector (.General Atomics RD-52) by the licensee using Kr-85 at 5E-5 uCi/cc and Xe-133 at 5E-4 and 5E-2 uCi/cc found significant variation from the calibration data supplied in the vendor's topical report, "General Atomics RD-52, E-115-647." The cause was thought to be erroneous calibration by the vendor. The licensee submitted a 10 CFR 50.55(e) Report dated July 21, 1982, regarding this subject. As of this inspection, the licensee had not yet received or reviewed a revised calibration and energy response topical report for the RD-52. The licensee's review and evaluation of this report will be discussed in a subsequent inspection (50-361/83-08-01).

- Calibration of the WRGM mid and high range detectors (General Atomics RD-72) by the licensee using Xe-133 at 5E-2 and 5 uCi/cc found signficant variation from the calibration data supplied in the vendor's topical report, "General Atomics RD-72, E-255-961." The licensee determined the cause to be the vendor's failure to install a spacer which properly positions the CdTe detector. The licensee also described this condition in the 50.55e Report noted above. The licensee informed the

inspector that GA Technologies has re-performed the RD-72 and RD-52 type calibration, however, they had not yet received the new topical reports. Evaluation of consistency between the new topical report and the licensee's enhanced calibration results will be reviewed in a subsequent inspection (50-361/83-08-02).

In the licensee's July 21, 1982 50.55(e) Report inconsistencies between vendor supplied flow calibration data and licensee measurements from stack flow transmitters were identified.

Subsequently, the licensee determined that a vendor wiring error and software deficiency resulted in only one stack area used to calculate flow regardless of the stack selected. being condition was corrected for the licensee's units. This Startup Problem Report No. 3498 documents a condition wherein the automatic shifting function from low to mid and high can be duped by an oscillation of radioactivity resulting range in a "mid/high range pump failure alarm" and loss of range overlap. The vendor issued Field Change Order 034 dated July 1, 1982, to correct this problem.

Based on tours of the Penetration Building, Control Room, and review of procedures and documentation, the licensee and was operating the main steam line radiation monitorshad installed described in the licensee submittal and TS 3.3.3.6. as Continuing evaluation of particulate and iodine sample characteristics of the WRGM system by SAI was in progress.

The inspector was informed that additional measurements have been taken since the last inspection. Review of final evaluation of sample line fallout characteristicsthe be made in a subsequent inspection (50-361/83-08-03). will B. Sampling and Analysis of Plant Effluents Technical Specification 6.8.4.d. Post-Accident Sampling in part that a program which will ensure the capability states and analyze radioactive iodines and particulates in to obtain effluents samples under accident conditions will be plant gaseous implemented, and maintained. The program shall include established, the training of personnel, the procedures for sampling and analysis and the provisions for maintenance License Condition 2.C.19(i) ofrequires sampling and analysis equipment.

that this program be fully implemented by January 1, 1983.

This requirement is in response to TMI Action Item (NUREGs-0660, II.F.l. Attachment 2. The licensee informed NRR (Item 0737)

"Radioiodine and Particulate Effluent Monitors," "ResponseII.F.l.2.0, Action Plan NUREG 0660") that: "The wide-range effluent to NRC provided with grab sample cartridges for collection monitor is of particulate and iodine samples. This sample will be analyzed onsite."

When asked by the inspector how this would be accomplished, several licensee representatives stated low level samples would be analyzed onsite and higher activity samples would be sent offsite to a contractor laboratory. Station Procedures S023-VIII-27.1 and S0123-III-5.3.23 were presented as the existing program.

Procedures S023-VIII-27.1, "Particulate and Radioiodine Sampling Using the Wide Range Gas Monitor (RE 7865, 7870) in a Post-Accident Situation," Revision 0, dated November 24, 1982, and S0123-III-5.3.23, "Unit 2/3 Radioactive Gas sampling and Analysis Procedures,"

Revision 0, dated November 20, 1982, were reviewed.

Handling and analysis of these potentially highly radioactive samples were discussed with responsible representatives of the Emergency Planning, Chemistry, and Health Physics Staffs.

Based on review of these procedures and as a result of discussions with licensee representatives, the inspector determined that:

- No preparations have been made for onsite analysis of charcoal or particulate samples with activity levels specified in S0123-III-5.3.23, Section 6.5.6.4, or USNRC Regulatory Guide 1.97, Revision 2.

- Section 6.2.1.6 of S023-VIII-27.1 is inconsistent with other sections of the procedure which call for offsite shipments if the dose rate from these samples is in excess of 0.05 mr/hr and S0123-III-6.3.23.

- The licensee apparently has a contract (P.O. No. S1692901) with GA Technologies to analyze higher activity particulate and radioiodine samples from inside containment, however no specific procedures to accomplish this action have been developed for post accident effluent samples.

Failure to develope a program which would insure the capability to analyze onsite post accident radioactive iodine and particulate samples represents apparent noncompliance with License Condition 2.C.(19)i and Technical Specification 6.8.4.d.

(50-361/83-08-04).

"C. Containment High-Range Radiation Monitor Inspection Report No. 50-361/83-04 documents review of installation and procedure implementation for the Containment High-Range Radiation Monitors 2RE7820-1 and 2RE7820-2. During this inspection, GA Topical Report No. E-255-978, "Energy Response Test and Dose Rate Calibration of Model RD-23, High-Range Radiation Monitor Detector," was reviewed. This report documents detector energy response from 60 Key to 3 Mev and linearity from 0.6 to 5.17 E6 R/hr.

The detector satisfies the criteria for energy response and linearity.

During tours of the Control Room, the inspector noted that 2RE7820-1 was in the alarm mode. This alarm had been acknowledged by the operator such that Annunciator Window 57C10, "High Range In Containment Monitor Radiation High," remained lit. It appears, based on work request data, that this condition may have existed since January 23, 1983. Two Startup Problem Reports Nos. 3916, dated October 28, 1982, and 4255, dated January 17, 1983, identify the alarm condition to be the result of an electronically unrealistic set point (2 R/hr). The monitor's range is from I to l.OE8 R/hr. The detector has an installed source which produces an equivalent dose rate of 1 R/hr. This means the alarm set point is very close to the instrument's limit of-accuracy (+3% of equivalent linear full scale). With one channel in alarm, the control console operator would not receive indication of an alarm from the other channel, 2RE7820-2.

The inspector discussed with licensee representatives the negative effect of having one channel in the alarm mode and the reporting requirements of TS 6.9.1.13.b. The licensee presented a memorandum dated February 9, 1983, from Bechtel Power Corporation to SCE recommending a change in the alarm set point. The licensee's action regarding this matter will be reviewed in a subsequent inspection (50-361/83-08-05).

In summary, one apparent item of noncompliance (50-361/83-08-04) and four inspector follow-up items were identified associated with the inspection of TMI Action Item II.F.I. Attachments 1, 2, and 3.

4. Post Accident Sampling System (PASS) Capability As a result of the accident at Three Mile Island. Unit 2, NRC determined that it is necessary for the licensees to be able to perform chemical and radiochemical analysis of the reactor coolant and containment atmosphere after an accident in order to assess the degree of core damage. In addition, these samples and analyses must be performed rapidly and without excessive radiation exposure to the workers involved.

The specifics of this requirement were presented in the following documents: NUREGs -0578, -0660, -0694, and -0737. Southern California Edison Company (SCE) described specific actions to be taken at Units 2 and 3 to satisfy this requirement in Section "II.B.3 - NUREG Post-Accident Sampling Capability," of their submittal to NRR titled, 0737 "Response to NRC Action Plan NUREG 0660 San Onofre 2 and 3." This information and subsequent correspondence provided the basis for NRC's conclusion-that an adequate system meeting the II.B.3 requirement would be installed prior to operation above 5 percent power (Safety Evaluation Report, NUREG-0712 Supplement No. 1). By letter dated December 22, 1981, SCE requested and was granted relief from the January 1, 1982 date based on delays in system material delivery (NUREG-0712 Supplement 4). With issuance of Facility Operating License NPF-l0 on February 16, 1982, a specific license condition, 2.C.(19)i, was included which stated:

"Post-Accident Sampling (II.B.3* SSER #1, SSER #4, Section 1.12, SSER #5)

Prior to exceeding five (5)percent power, the post-accident sampling system shall be operable and the post-accident sampling program shall be fully implemented."

The post-accident sampling program was addressed in Section 6.8.4 of the Technical Specifications. This section states in part that:

"The following programs-shall be established, implemented, and maintained:...

Post-Accident Sampling A program which will-ensure the capability to obtain and analyze reactor coolant, radioactive iodines and particulates in plant gaseous effluents, and containment atmosphere samples under accident conditions. The program shall include the training of personnel, the procedures for sampling and analysis and the provisions for maintenance of sampling and analysis equipment."

By letters dated September 11, 14, and 15, 1982, the licensee requested was granted a delay in implementing Licensee Condition 2.C.(19)i until and January 1, 1983 (Amendment No. 8 to NPF-lO, dated September 17, 1982).

According to the licensee, this delay was necessary-due to problems in design, material lead time, and a number of hardware problems which collectively prevented the system from being declared operable.

On December 21, 1982, the licensee submitted a letter to Mr. G. W. Knighton of NRR which stated in part that:

"Improvements and modifications, as di-scussed in Reference "C" and in a meeting with NRC staff on September 13, 1982, have been completed. Testing of each individual item has also been completed.

On the day that the PASS Demonstration Test was to be performed, SONGS 2 tripped while operating at the 50 percent power level.

The plant remains in a shutdown condition to replace reactor coolant pump seals. With the plant shutdown, it is not possible to complete the PASS Demonstration Test or to implement the enhanced operator training on the system after the demonstration test.

SONGS 2 is expected to return to power by early January, 1983, at which time the PASS Demonstration Test will be completed and operator training will be conducted. In the meantime, SCE considers the PASS to be operable and License Condition 2.C(19)i to be satisfied."

Based on this letter and discussions with licensee representatives during an inspection the week of January 17-21, 1983, the inspector advised the licensee representatives that compliance with the PASS requirements would be inspected sometime after January.31, 1983.

During the entrance interview on February 7, 1983, in response to questions from the inspector, Station Management stated that the PASS was operable and that the licensee was in compliance with Technical Specification 6.8.4.d.

Later that day, the Lead Technical Compliance Engineer informed the inspector of the station position, that a demonstration test had successfully been conducted on January 22, 1983, that the station had not yet accepted the system from the startup group, that the demonstration test could be used to operate the system, and that the classroom training of chemistry technicians had been completed.

On February 8, 1983, the inspector confirmed by discussion with the Unit 2 Chemistry Supervisor that no technicians had actually drawn samples using the PASS. Two technicians were actively involved in receiving on the job training using a draft version of the system operating procedures.

At the close of business, on February 8, 1983, the inspector was shown a letter dated February 9, 1983, from K.P. Baskin (SCE) to G. W. Knighton (NRC) which stated in part that "Station operating procedures and 'hands-on' training will be completed by March 1, 1983 providing continued operation of Unit 2," and that personnel qualified to operate the system were available.

On February 9, 1983, the inspectors met with the cognizant station and startup engineers to review the demonstration test package. The inspector was informed that these engineers Cor others) using the "Demonstration Test" procedure would operate the PASS should a sample be necessary.

Based on review of the "Demonstration Test" 2AC-228-01, Revision 0, and discussions with these engineers the inspector observed:

2AC-228-Ol referenced S0123-III-8.2.23, "Unit 2/3 Startup and Fill of the Post-Accident Sampling System," and S0123-III-8.3.23, "Unit 2/3 Sampling Procedures and In-Line Analysis for the Post-Accident Sampling System," as the step-by-step direction by which to operate the PASS. The engineers acknowledged that these procedures (Revision 0, dated December 2, 1982) were inadequate due to extensive system modification. They stated that during the Demonstration Test changes were made in order to collect and analyze the samples. These changes were not documented as Temporary Change Notices (TCNs). Therefore, the completed 2AC-228-01 did not constitute an approved procedure which could be reused in a step-by-step. manner to operate the PASS.

Emergency Plan Implementing Procedures S023-VIII-46.1 thru 46.4 issued April 8, 1982, also covered operation of the PASS. On February 17, 1983, the cognizant engineer informed the inspector by telephone that these procedures were also in error and should have been cancelled.

Test Exception Reports (TEP) were issued for failure to meet the acceptance criteria for oxygen and boron. In addition, a TEP should have been issued for the total gas analysis as this value slightly exceeded the established limit.

The "Demonstration Test" was not an integrated system checkout in that it did not include the on-line gamma spectroscopy unit.

The test did not include collection of an undiluted sample for offsite analysis.

Note: The licensee has purchased a shipping container purpose, however, the unit has not yet been issued for this a Certificate of Compliance by NRC.

No specific frequency or acceptance criteria had which would require periodic use of the system to been established demonstrate operability.

Based on these observations the inspector stated that informalities and incompleteness of the "Demonstration due to package, it did not appear to satisfy the program Test" requirement of TS 6.8.4.d.

The Station Manager, on being informed of this finding, that on February 10, 1983, a sample of the Unit directed 2 reactor coolant system would be performed using approved procedures the operability of the system and its capability which demonstrate to meet the criteria presented in the licensee's response to TMI Action Item II.B.3.

On February 10, 1983, at 12:30 p.m., the inspectors and licensee representatives met at the PASS Laboratory. The licensee written, reviewed, and issued Revision l to S0123-III-8.2.23, had 8.3.23, 8.4.23, and 8.7. Ground rules were established sample of reactor coolant would be collected and that a for pH, boron, hydrogen, oxygen, total gas and gammaanalyzed isotopic activity within three hours by cognizant engineers using approved procedures. Procedures would not be violated. the changes were necessary, the time required to process If TCNs would be included in the three-hour limit.

At 1:30 p.m., S0123-III-8.2.23, "Startup And Fill Sample System," was initiated. The time involved of The Post-Accident procedure was not counted against the three-hour to complete this limit since it could normally be completed prior to the decision to actually take a sample. S0123-III-8.2.23 was completed at 4:10 p.m.

At 4:15 p.m., an actual sample in accordance with Revision 1, "Sampling Procedures and In-Line Analysis S0123-II-8.3.23, for the Post-Accident Sampling System," was initiated.

At 4:40 p.m., the licensee recognized that step 6.0.3 could not be followed. This step involved establishment of proper burette and surge vessel levels. TCNs were prepared and issued to S0123-III-8.2.23, 8.3.23, and 8.4.23 at 6:25 p.m. During the sampling effort, the inspector identified three leaks on the sample system lines which needed repair. At 8:45 p.m. the licensee concluded the sample effort. Acceptable results for pH, boron and total gas were measured. Apparent system in-leakage resulted in an unacceptably low hydrogen concentration and a oxygen concentration in excess of the total gas value (including oxygen).

The insector informed licensee representatives that the system was not operable in that: a sample could not be collected and analyzed within three hours in accordance with S0123-II.8.3.23; acceptable results for hydrogen and oxygen were not achieved; and observed leakage in accident conditions would likely have resulted in unnecessary radiation exposure to the workers.

As part of the PASS system operability demonstration, the inspector observed operation of the Inline Gamma Spectrometry System in accordance with Chemistry Procedure S0123-III-8.7, Revision 1, "Operation and Calibration of "PASS" Laboratory Gamma Spectrometer."

During the test, the licensee had to issued a Temporary Change Notice (TCN) in accordance with plant procedures in order to correct minor omissions in the procedure. In addition, due to a loose connector, it appeared that the licensee would not have been unable to perform a energy efficiency correction and isotopic identification of the acquired spectrum. Inoperability of.the system was identified by a vendor representative present during the test. The licensee was able to find and correct the problem after being informed that a problem existed by the vendor.

The inspector discussed with licensee representatives concerns regarding inadequate procedures and the.vendor's intervention. The inspector was advised that a revised procedure had been prepared and will be modified as technician training reveals additional deficiencies.

The .inspector informed the licensee representatives that on February 10, 1983, the PASS System was not fully operable due to the described mechanical problems, that proper procedures did not exist to ensure meeting TS 6.8.4.d. and that Licensee Condition 2.C.(19)i was not met. It is apparent that prior to this date, a program, per 2.C.(19)i, had not been fully implemented but that certain startup personnel could operate the system if necessary.

It should be noted that at the time of this inspection other avenues existed for taking II.B.3 samples due-to the low fission product inventory.

Failure of the post-accident sampling system to be operable and the post-accident sampling program to be fully implemented on February 10, 1983, represents apparent noncompliance with License Condition 2.C.(19)i (50-361/83-08-04).

On February 10, 1983, the licensee provided the inspector a copy of SCE Corrective Action Request (CAR) S023 P-325 dated January 31, 1983.

The CAR stated:

"Amendment No. 8 to Facility Operating License NPF-1O for San Onofre Nuclear Generating Station, Unit 2, Paragraph 2.C.(19)i states... 'By January 1, 1983, the post-accident sampling system shall be operable and the post-accident sampling program shall be fully implemented.'

Contrary the above requirement, the post-accident sampling program has not been fully implemented in that adequate system operating procedures have not been approved or issued for use and operator training on the system has not yet been conducted."

In accordance with 10 CFR 2, Appendix C, "General Policy and Procedure for NRC Enforcement Actions," a Notice of Violation may not be issued for a violation provided:

(1) It was identified by the licensee; (2) It is severity level IV or V; (3) It was reported, if required; (4) It will be corrected within reasonable time; and (5) It was not a violation that could have been prevented by corrective action for previous violations.

Based on inoffice review of License No. NPF-lO, the inspector notes that License Condition 2.G states:

"SCE shall report any violations of the requirements contained in Section 2, Items C(l), C(31 through C(22), E, and F of this license within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by telephone and confirmed by telegram, mailgram, or facsimile transmission to the NRC Regional Administrator, Region V, or his designee, no later than the first working day following the violation, with a written followup report within fourteen (14) days."

Review of Region V correspondence found no report indicating that SCE had informed the Regional Administrator of failure to comply with 2.C.(19)i after January 31, 1983 (the date of the CAR). On February 25, 1983, the Deputy Station Manager acknowledged that a report pursuant to 2.G had not been submitted.

The Deputy Station Manager discussed the need for this report with the inspector in view of the inspection findings. The inspector advised that a late report is better than no report.

Failure to submit a timely report of a violation of License Condition 2.C.(19)i represents noncompliance with License Condition 2.G (50-361/83-08-06).

5. Exit Interview The inspector met with the licensee representatives (denoted in paragragh 1) at the conclusion of the inspection on February 11, 1983.

The inspector summarized the scope and findings of the inspection.

Regarding the Containment High Range Radiation Monitor, the inspector directed the licensees' attention to the reporting requirement of Technical Specification 6.9.1.13.b.

In response to the finding that the PASS was not operable and a program satisfying License Condition 2.C.(19)i was not in place, the licensee stated that application for a revision to the license condition would be submitted.

REFERENCE C

- " t UN SIAIES C832 C G "NUCLEAR REGULATORY COMMISSION 14150 A4Aa L~AWiSvi.t :"4- -

- %AI.NUT CAEFKP CAj.1*OS-iA 44!,q(

f~1228 Docket No. so-3bl, 50-361 NOV 161983 J - "

Southern California Edison Company 2244 Walnut Grove Avenue Rosemead California 91770 Attention: Mr. Charles B. McCarthy. Jr., Vice Pr-sident Advanced Engineering Gent Iemen:

Suhject: NRC Inspection San Onofre Units 2 and 3 This refers to the routine inspection conducted by Mr. C. Sherman of this office on October 17-20, 1983. of activities authorized by&HRC License No.

NPF-l0, NPT-15 and to the discussion of our findings held Mr. Sherman with Mr. J. Haynes and other members of your staff at the concldsion of the i nspection.

Arera examined during this inspection are described in thekenclosed inspection report. Within these areas, the inspection cons.isted of s4lective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.

No items of noncompliance with NRC requirements were ident fied within the scope of this inspection.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days ot the date of this letter. Such application mUst be consistent with t"-h requirements of 2.790(b)(1).

I, , .,I C A .*:'r*:

Southern California Edison Company -2 - NV1~ 18 be glad to Should you have any questions concerning this inspection, we will discuss them with you.

Sincerely, F. A. Wenslawski, Chief Radiological Safety Branch

Enclosure:

Inspection Report No. 50-361/83-37 50-362/83-35 cc w/o enc:

D. J. Fogarty, Executive Vice President H. B. Ray, Site Manager (San Clemtnte)

I, I

I U. S. NUCCLEAR REGULATORY COH1h7SSION C83120 IG- /L REGION V Report Nos. 50-361/83-37, 50-362/83-35 Docket Fos. 50-361, 50-362 License Nos. NP:F-10, NPF-15 Licensee: Southern California Edison Company P. 0. Box 800, 2244 Walnut Grqve Avenue :1 Roseme3d, California 91770 Facility Name: San Onofre Unita 2 and 3 Inspection at: San Clemente, California Inspection cooducted: October 07 through 20, 1983 Inspectors:

C. 1. Sherman, Radiation Specialist Date Signed Approved By: / 4ez A. Wenulawski, Chief Dýt e S ned

?Radiological Safety Branch Summnary:

Ing ecLion ot. October 17 through 20, 1983 (Report Nos. 50-361/83-37 And 50-362/83-35)

Areas Inspected: Routine unannounced inspection to review the licensee's actions regarding previous Jnspection findings, Licensee Event Report "No.-83-17-L and items of noncompliance. The inspection involved 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> onsite by one regionally oased inspector..

Resu]lts: Of the 3 areas inspected no items of noncompliance or deviations were identified.

b,

DETAILS

1. Persons Contacted

• J. Haynes, Station Manager

• W. Moody, Deputy Station Manager

1. • P. Knapp, Health Physics Manager

• R. Rosenblum, Station Technical Manager

1. • J. Droste, Assistant Technical Manager

• G. Gibson, Supervisor, Compliance, Configuration and Control

• R. McWey, Chemist

• D. Brevig, Supervisor, Nuclear Plant Chemistry

• R. Reiss, Quality Assurance Engineer

• R. Santosiosso, Super'4sor, Instrumentation and Control

1. • E. Goldin, Health Physics Engineer

• J. Wambold, Maintenance Manager

1. R. Warnock, Supervisor, Health Physics Engineering

• K. Helm, Effluent Engineer J. Trimble, General Atomics

• D. Schone, Quality Assurance Manager D. Sticknty, Instrumentation and Control Engineer H. Mathis, Training Manager M. Rhoides, Nuclerr Chemistry Technician J. Scott, Training Instructor D. Todd, Nuclear Chemistry Technican C. Spoonmore, Training Instructor

• Indicates those individuals attending the exit interview on October 20, 1983.

1. Indicates those individuals participating in telephone call un October 25, 1983.

2. Licensee Action on Previous Inspection Findinks (Closed) (50-361/83-08-06) Item of ooncompliance related to failure to submit a timely report of a violation of License Condition 2.C.(19)i as required by License Condition 19.G.

The inspector reviewed the SCE response to the Notice of Violation, specifically the corrective steps taken to avoid further violations. In discussion with licensee representatives, the inspector noted that the special review meetings identified as a corrective step in the enclostire to the May 2, 1983 letter have been conducted for the Post Accident Sample System (PASS) and other regulatory requirements.

(Closed) (50-361/83-08-04) this item of noncompliance was related to failure of Post Accident Sampling System to be operable and the Post Accident Sampling Program to be fully implemented in accordance

- lluzz

"2 with facility License Condition (License No. NPF-10) 2.C.(19)i. and T.S. 6.8.4.d. Following the inspection resulting in this item of noncompliance, license condition 2.C.(19).i was amended (No. 17 for NPF-10 lzd No. 5 for NPF-15) to read as follows:

Post Accident Samvling System (NUECG-0737 Item II.B.3)

I. By June 1, 1983, SCE shall substantially complete all of the PASS procedures identified in Enclosure 3 of the SCE letter of April 14, U 1983.

2. Prior to September 1, 1983, SCE shall maintain in effect all compensatory measures other than the PASS that are identified in the SCE letter of April 14, 1983, that are not already covered by Technical Specification surveillance requirements.

3. By September 1, 1983, the PASS shall be operable and the post accident sampling program shall be implemented.

4. Until September 1, 1983, SCE shall provide monthly progress reports on PASS testing, surveillance, maintenance and modifications, and operator training.

This inspection verified that these new license conditions were satisfied.

a. Procedures The SCE letter of April 14, 1983 (R. Dietch to H. Denton) identifies 32 procedures in place as of April 4, 1983. The inspector verified that these procedures were issued and that additional procedures identified were in place at the time of the inspection. Additional procedures were issued subsequent to the April 14 letter. i The following procedures were reviewed:

No. Procedure No. Title

1. (/. S623-I-8.130 PASS Semi-Annual Preventative Maintenance

2. S023-1-8.131 PASS 18-Month Preventative Maintenance

3. S023-1-8.132 Refueling Interval PASS Air Cleanup System Charcoal Absorber Testing

4. S023-1-8.133 Refueling Interval PASS Air Cleanup System HEPA Filter Testing

3 5, S023-71-4,45 PASS Area Radiation Monitors Channel Calibration

6. S023-1-8.10 Loop Verification

7. S023-II.9.361 Cootainment High Range Area Radiation Monitor Calibration

8. S023-II-9.362 Ares Radiation Monitor Readout Calibration 9, 5023-11-9.363 Area Radiation Monitoring System Calibration

10. S023-11-8.772 PASS Instrumentation Loops Calibration Ii. S023-1I.9.191 Sigma Indicator Model 9263 Calibration

12. S023-11-9,384 Sigma Boron Meter Model 9262 Converter Calibration

13. S023-II-9.382 PASS Liquid and Gaseous Flowmeter Calibration

14. S023-II-9.10 Rosemount Differential Pressure Transmitter Calibration

15. S023-11-9.37 Pneumatic Valve Calibration

16. S023-II-9.351 Fischer Porter Manual Station Calibration

17. S023-II-12.446 PASS Instrumentation Calibration

18. S023-II-9.383 Beckman pH Analyzer Model 940B Calibration

19. S023-II-9.381 Delphi Model "B" Thermal Conductivity Analyzer Calibration

20. S023-11-9.82 Pressure Switeh Calibration

21. S023-II.9.380 Delpha Paramagnetic Oxygen Analyzer Model 'J' Calibration

22. S023-11-9.193 Thermon Temperature Indicating Controller Calibration

4

23. S0123-III-8.0 PASS Sampling Program and Analytical Requirements

24. S0123-IIl-8.1 PASS Routine Surveillances

25. S0123-III-8.2.23 Purge and Fill of the PASS

26. S0123-III-8.3.23 Sampling Procedures and In-Line Analysis for PASS

27. S0123-III-8.4.23 Purging and Refilling of the PASS (cancelled)

28. S0123-III-8.5.23 Chemistry Calibration Procedure for PASS

29. S0123-III-8.6.23 Access to the PASS During Accident Conditions

30. S0123-111-8.7 Operation and Calibration of PASS Spectrometer

31. S0123-III-8.8 Alternate Methods of Post Accident Sampling

32. SO123-II-8.9 Operation and Calibration of the ND-SIX 33, 111.8.10.23 Radioactive Iodine and Particulate Sampling Under Accident Conditions

34. S0123-VII 8.11 Movement of Emergency Samples at SONGS

35. S0123-VIl 8.11.2 Handling and Shipping of Undiluted Pass Samples S0123-VII 8.11.2 Shipment of Wide Range Gas Monitor 36.

Samples

37. S0123-G-19 PASS Program

38. Table 15 EOF Interim Procedure for Core Procedure Damage Assessment

39. General Atomic Post Accident Sample Cask Receipt Procedure and Chloride Analysis ACD:EL:O01A

5 Based upon the review of procedures and other documents, the inspector concluded that the procedures identified in the April 14 and May 2, 1983 (L. Papay to R. DeYoung) letters were substantially complete at the time of the inspection and had been issued prior to June 1, 1983.

b. Compensatory Measures Compensatory measures identified in the April 14 letter (Enclosure 5) are incorporated in procedure S9123-8IIo8.8, "Alternate Methods of Post Accident Sampling". The inspector reviewed this procedure to insure that compensatory measures were consistent with those discussed in the April 14 letter and SER NO. 17.

Compensatory measures consist of those covered by technical specification requirements, calculational methods and radiochemistry laboratory equipment. Principal compensatory measures not covered by other technical specification requirements Identified in procedures S0123-1l1-8.8 are as follows:

PASS Function Alternate Method Hydrogen or Total Gas in RCS Calculation based on Pressure and Temperature from Plant Computer Containment Atmosphere Grab sample from effluent Hydrogen monitor 7804 Boron Concentration Calculation For each PASS function, diluted grab samples were available from PASS for radiochemistry laboratory analysis and undiluted grab samples were available from the radiochemistry laboratory sample station.

The inspector also reviewed S0123-III-B.1," Post-Accident Sampling--System Routine Surveillances". This procedure provides for comparison of PASS values with those obtained by routine radiochemistry procedures. Acceptance criteria are as described in the April 14 letter.

The inspector reviewed records of surveillance activities from June 1983 to date. In each case where a primary PASS instrument was out of service, alternate A methods were available to perform the required analysis.

6 During the mid June to August PASS outage, the diluted grab sample capability was not available and compensatory measures available were based on technical specification required monitors. The inspector noted that in the event of high radiation levels precluding the use of the normal sample station and the PASS diluted sample capability inoperable, no alternate methods would be available onsite for pH, reactor coolant radionuclides or chlorides. These limitations are discussed in SER No. 17.

Based on review of PASS routine surveillance records, other records maintained to indicate availability of alternate methods, review of procedures, and discussion with personnel the inspector concluded that adequate compensatory measures were in effect during periods of PASS inoperability.

c.l Operability The inspector reviewed surveillance records associated with S0123-III-8.1 for September. The inspector noted that the Boron instrument did not meet surveillance acceptance critiera on August 31, 1983. This was noted in the monthly report dated September 6, 1983. Alternate methods were available.

Review of Instrument Calibration Data Cards (ICDC) for this instrument indicated that this instrument was recalibrated on (

September 9, 1983 and that acceptable surveillance tests were performed on September 22 and October 13, 1983. A licensee representative indicated that calibration was found to be temperature sensitive and that actions had been taken to improve the calibration program for this instrument. The inspector noted that all other PASS instruments met their surveillance criteria during the August 31 test.

The inspector concluded that the PASS was operable on September 1, 1983.

c.2 Pass Program The Post Accident Sampling Program as defined in Technical Spetification 6.8.4.d (NPF-10) states, "A program which will ensure the capability to obtain and analyze reactor coolant, radioactive iodines and particulates in plant gaseous effluents, and containment atmosphere samples under accident conditions. The program shall include the training of personnel, the procedures for sampling and analysis and the provisions for maintenance of sampling and analysis equipment."

I

7 As described above, the inspector reviewed pr°cedures for sampling and analysis. The training of personnel and provision& for maintenance were also reviewed.

With respect to training, the inspector reviewed training records, lesson plan outlines and discussed PASS training Itb two chemistry technicians. Based upon review of these items and other documents and discussions, the inspector concluded that the training portion of the PASS program was implemented.

With respect to maintenance, the inspector discussee and/or reviewed portions of the I&C instrument maintenance and maintenance department equipment maintenance programs. Based on these reviews, the inspector concluded that the licensee had provided for maintenance of sampling and analysis equipment.

d. Progress Reports:

The inspector verified that monthly progress reptrts were submitted in June, .uly, August and September. These reports covered the required areas. The inspector did not note any facts conflicting with information developed during the inspection process.

In sumnary, based on detailed review of records, procedures other documents and discussions with personnel, License Condition 2.c.(19).i as related to NMEG-0737*Item III.B.3 is satisfied. The inspector had no further questionslon this matter.

(Closed) 50-362/83-08-04) Item of noncompliance related to the failure to develop a program to analyze onsite post accident radioactive iodine and particulate samples pursuant to .IJRG 0727, !tam I.F.1, Attachment 2, as required by License C~zdi:icn 2.C.(]P)i and Technical Specification 6.8.4.d.

The inspector reviewed training of personnel, procedures for sampling and analysis, and provisions for maintenance.

a. Trainin . The inspector noted that the licensee provided training to address operation and sampling the wide range gas monitor (WRGM) during accident conditious. The inspector reviewed training records of Nuclear Chemistry' Technicians (NCT) qualified to operate rASS, discussed the training program with the instructor, the chemistry manager, and two PASS qualified NCT. The inspector concluded, based upon these reviews that the training program was adequate.

b. Procedures for Sampling and Analysis The inspector reviewed procedures previously identified as %tos. 32.

33, 35 and 36. Except as noted in (d), these procedures appear to adequately address sample removal, transport, analysis, and offaite shipment of WR4S samples,

8

c. Maintenance: The licensee stated that wide range gas monitor maintenance is provided for under normal plant surveillance procedures which are conducted on a quarterly frequency. The inspector reviewed procedures for 92 day channel functional test and 18 month channel calibration. The inspector was satisfied that these procedures form an adequate basis *or a maintenance program.

d. Additioual Review II.F.1, Attachment 2. This item provides a criterion to collect and anolyze radioactive iodine and particulate during and following and accident. Clarification (2) states that the system design shall be such that plant personnel could remove samples, replace sample media and transport samples to the onsite analysis facility with I radiation exposures not exceeding general design criteria (dDC) 19 (20 CFR 50, Appendix A) of 5 rem whole body. Discussiong with licensee staff indicated personnel apparently believed retrieval of samples from the wide range gas monitor (WRGM) could be delayed as long as necessary following an accident in order that radiation doses could be kept below rem. In order to cfairfy the licensee position, the inspec or conducted additional discussions with the licensee.

The iuspector reviewed a memo dated April 15, 1983 from E. Golden to F. Brijgs which discussed Post-Accident dose rites at the WRGM sample skids. This memo concluded that WRGM filter collection might hive to wait 10 days in order to limit whore body dose to one individual to 5 rem. This memo assumed a severe LOCA event releasing 100% of the noble gas inventorylto containment and leakage (20% of technical specification) through a containment penetration to the mini-purge duct. is memo provided radiation exposure rates at the WRGM skid as function of time following shutdown for each source (containment, hPSI,ILPSI, etc.) and a total exposure rate on all sources. Data for this memo was provided by Bechtel. e licensee made additional calculations to estimate the contribution from containuient purge and mini purge valve leakage.

In a telephone conservation with license representatives denoted in paragraph I on October 25, 1982, additional information was provided to the inspector. This informatio was based on revised assumptions concerning leakage, t attenuation of radiation by the ventilation duct And the I assumption that activity on the WRGM filters could be limited so that retrieval would not be encumbered by a bulky shield.

i

9 Based on licensee provided figures, the inspector tabulated he following information:

Persons required Dose Rate retrieve filter w h Time at WRGf 30 minute removal From Shutdown(hr) SKID (R/hr) time limiting dose rem 0.5 48.4 5 I hr 43 5 2 37 4 4 26 3 8 14.5* 3 24 6.3* 1 48 3.0* 1

• Numbers estimated by inspector from values provided.

The inspector indicated to licensee representatives that their system did not appear to meetItthe intent of XUREG-0737, Item II.F.1-2 in that a significant time delay was necessary before one person could be expected to retrieve a sample. The inspector noted that procedur4SO123-1!-8.1O.23 addressed sample activity, dose rates a the WRGM skid and delay in taking the sample due to the rapid reduction in dose rate in the first few hours following;Peactor shutdown, The procedure did cot address the possible need to use more than one person to retrieve a sample.

This aspect of acceptability of the licensee's.fesponse to item II.F.1-2 has been referred to M for review and will be evaluated in a subsequent inspection (Open, 50-361/83-37-01).

3. Licensee Event Report No.83-017 (Closed) (83-17-L), (Closed)(83-08-05). On JanuAry 24, 1983, the licensee determined that continuing alarms on the containment high range monitor were defeating its function. This evaluation was made following observations by an NRC inspector on January 21, 1983. The inspector reviewed licensee followup, actions which included a Technical Specification revision of the Alarm Point from 2R/hr to 10R/hr and addition of a second alarm indicator light.

4. Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) at th..conclusion of the inspection on October 20, 1983. The inspector summarized the scope and findings of the inspection.

Regarding accesL to the wide range gas monitor, the licensee stated that additional eviluation would be completed to refine projected exposure rates following an accident.

4

V.d 1A C8 4,;.. - (

AD12-QL

,. V,,

• ,, SONGS 2 & 3 November 18, 1983 HAROLD B. RAY

SUBJECT:

• NRC Inspection Report-Nos. 50-361/83-37 and 50-362/83-35 San Onofre Nuclear Generating Station, Units 2 and 3 Attached for your information and appropriate action is, a copy of the subject report covering inspctlons orOc~beTV 17 X X through Oc6bek20, 1983.X - ,- //. -

Areas inspected were licensee's actions regarding previous inspection findings, License Event Report No. 83-17-I.

and items of noncompliance.

• AL No items of noncompliance or deviations were identified.

One new open item (50-361/83-37-01) was identified regarding retrieval of samples from the wide-range gas monitor (WRGM) following an accident.

If you have any questions, please contact me.

. M.CRAN GFEgan: 4 1 7 4Q Attachment cc: Kenneth P. Baskin M. 0. Medford C. B. McCarthy W. C. Moody D. E. Nunn P. A. Croy J. M. Curran H. E. Morgan J. A. Beoletto R. M. Rosenblum H. S. Leasure P. J. Knapp Il.'

U-'.,,

W. M. Schwab D. A. Herbst K. G. Grothues D. B. Schone E. N. Cramer G. F. Egan D. F. Pilmer .,QA File W. W. Strom SCDM Center.,

t.

UNITED STATES C831201G- 0G i

ION ,

kI NUCLEAR REGULATORY COMMISc REGION V 1450 MARIA LANE SUMTE210 AAALNUT CREEK CALIFORNIA 9&5*

11S

,:*"18 *M 12 2B Docket No. 50-361. 50 NOV I... 1983 J. :' !--:- -

Southern California Edison Company 2244 Walnut Grove Avenue Rosemead California 91770 Attention: Mr. Charles B. McCarthy, Jr., Vice President Advanced Engineering Gentlemen:

Subject:

KRC Inspection San Onofre Units 2 and 3 This refers to the routine inspection conducted by 'r. C. Sherman of this office on October 17-20, 1993. of activities authorized by NRC License No.

NPF-l0, NTF-15 and to the discussion of our findings held by Mr. Sherman with Mr. J. Haynes and other members of your staff at the conclusion of the inspection.

Areas examined during tbis inspection are described in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.

No items of noncompliance with NRC requirements were identified within the scope of this inspection.

In accordance with 10 CFR 2.790(a). a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the requirements of 2.790(b)(1).

.1. .

,.. .3, C. R. t.o.;,.,*

Southern California Edison Company - 2 " NOV I P1983 inspection, we will be glad to Should you have any questions concerning this discuss them with you.

Sincerely, F. A. Wenslawski, Chief Radiological Safety Branch

Enclosure:

Inspection Report No. 50-361/83-37 50-362/83-35 cc w/o enc:

D. J. Fogarty, Executive Vice President H. B. Ray, Site Manager (San Clemente)

REFERENCE D

,-00* UNITED STATES

. -,NUCLEAR REGULATORY COMMISSION REGION V 1450 MARIA LANE, SUITE 210 WALNUT CREEK C0JF, RNIA 94596 Q ~j~  : rUA(1 - I986 Docket Nos. 50-206, NUCO~R UCESING 50-361 and 50-362 Southern California Edison Company J. N'. CtNRA'*

2244 Walnut Grove Avenue J- A'I Rosemead, California 91770 Attention: Mr. Kenneth P. Baskin, Vice President Nuclear Engineering, Safety and Licensing Department Gentlemen:

Subject:

NRC Inspection San Onofre Units 1, 2 and 3 This refers to the inspection conducted by Messers. H. North and J. Moore of this office on January 13-17 and February 3-7, 1986, of activities authorized by NRC License Nos. DPR-13, NPF-10 and NPF-15 and to the discussion of our findings held by Messers. North and Moore with Mr. H. E. Morgan on January 17 and February 7, 1986, and other members of your staff at the conclusion of the inspection.

Areas examined during this inspection are described in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.

No violations of NRC requirements were identified within the scope of this inspection.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room.

Should you have any questions concerning this inspection, we will be glad to discuss them with you.

.i erely, /

F. A. Wenslawski, Chief Emergency Preparedness and Radiological Protection Branch

Enclosure:

Inspection Report Nos. 50-206/86-02, 50-361/86-02 and 50-362/86-02 cc w/enclosure:

D. J. Fogarty, SCE H. B. Ray, SCE (San Clemente)

H. E. Morgan, SCE (San Clemente)

State of CA

U. S. NUCLEAR REGULATORY COMMISSION REGION V Report Nos. 50-206/86-02, 50-361/86-02 and 50-362/86-02 Docket Nos. 50-206, 50-361 and 50-362 License Nos. DPR-13, NPF-10 and NPF-15 Licensee: Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, California 91770 Facility'Name: San Onofre Nuclear Generating Station - Units 1, 2 and 3 Inspection at: San Onofre Nuclear Generating Station Inspection Conducted: January 13-17 and February 3-7, 1986 Inspector: f 36 9 HS. rth, Senij Radiation Specialist Date Si*;ned J. z* )ýore,--Radl~tion Specialist Ditel Si*

ued Approved By

os

c. P.. Yii Chief Rdt, Facilitiee;Radiation Paie Si gned Protection Section Summary:

Inspection on January 13-17 and February 3-7, 1986 (Report Nos. 50-206/86-02, 50-361/86-02 and 50-362/86-02)

Areas Inspected: Routine, unannounced inspection of licensee action on previous inspection findings, review of licensee reports, gaseous waste systems, radiological environmental monitoring, occupational exposure during extended outages, Unit 3 fuel fragment contamination, facility tours and followup on Information Notices. Inspection procedures addressed included 83729, 80721, 84724 and 65051.

Results: Of the areas inspected, no violations or deviations were identified.

1. Persons Contacted

• +H. Morgan, Station Manager

• M. Wharton, Deputy Station Manager A. Abusamra, PASS Chemistry

• J. Albers, Supervisor Unit 2/3 Health Physics (HP)

J. Anaya, Supervisor Unit 1 Instrumentation J. Beebe, Supervisor Unit 1 Radiation Monitoring Instrumentation

• E. Bennett, Quality Assurance (QA) Engineer

+L. Bray, HP Engineer D. Brevig, Senior Project Engineer

• J. Curran, Manager QA R. Dickey, Supervisor Dosimetry

• M. Freedman, Compliance Engineer

• G. Gibson, Supervisor Compliance

• +K. Helm, Effluent Engineer

• +R. Jervey, QA Engineer

+C. Kergis, Compliance Engineer

• +P. Knapp, Manager HP J. Madigan, Supervisor Unit 1 HP

+J. Mundis, Supervisor Nuclear Services

• J. Reilly, Manager Station Technical

• +D. Schone, Site QA Manager

• R. Warnock, Supervisor HP Engineering M. White, Environmental Engineer

+W. Zintl, Manager Compliance

• Denotes attendance at the January 17, 1986, exit interview.

+Denotes attendance at the February 7, 1986, exit interview.

In addition to the individuals identified above, the inspectors met and held discussions with other members of the licensee's staff.

2. Licensee Action on Previous Inspection Findings (Closed) Followup (50-361/83-37-01)

Inspector identified item related to the proposed use of multiple persons to collect high activity particulate and iodine WRGM samples following an accident to control individual exposures within GDC 19 limits.

Inspection Report No. 50-361/83-37 noted that the proposed use of several persons to limit exposures was to be discussed with NRR. NRR concurred with the proposed solution. Licensee procedure S0123-III-8.10-23 Rev. 3 had been revised to address manpower requirements for sample collection post accident. This matter is considered closed.

(Closed) Followup (50-361, -362/84-12-03)

Inspector identified item relating to the licensee's failure to declare an "Unusual Event" on June 2, 1984. In response the licensee issued Special Order, Number 84-13, dated May 7, 1984 Significance of:Effluent

2 Monitor Alarms and subsequently completed (July 11, 1984) issuance of Temporary Change Notices (TCNs) to numerous alarm response procedures to assure that they led to EPIP S023-VIII-I Recognition and Classification of Emergencies. This matter is considered closed.

(Open) Followup (50-206/85-29-01)

Inspector identified item relating to the disposal of SNM contaminated Nuclear Assurance Corporation cask waste. The waste has not been shipped to a burial site. The licensee is corresponding with NRC concerning the disposal. This matter will be reviewed during a subsequent inspection.

(Closed) Followup (50-206, -361, -362/85-10-21)

Inspector identified item related to qualification and training of persons conducting sampling activities. Three Unit 2 LER's relating to sampling and analysis discrepancies (85-25, -26, -48) were examined. The licensee's corrective actions were verified. Chemistry technicians and plant equipment operators were interviewed. Samples to be collected during the next shift were documented and passed on to the incoming chemistry shift. Chemistry technicians had been trained in sampling techniques and sampling locations. Responsibility for sample collection was assigned to chemistry and there was no evidence to indicate that this responsibility had been redelegated to another segment of the staff.

This matter is considered closed.

(Closed) Followup (50-362/82-15-03)

Inspector identified item related to adequacy of the radwaste building and compactor ventilation system. Previously addressed in Inspection Report No. 50-362/82-20 and 82-34.

Documents examined:

Letter, H. B. Ray, SCE to R. H. Engelken, NRC dated November 5, 1982, documenting commitments concerning the ventilation system; San Onofre Commitment Register System (SOCR) entries related to Inspection Report No. 50-362/82-15 and supporting documents; and Memorandum: Warnock to Knapp, April 8, 1985,

Subject:

DAW Compactor Ventilation Evaluation.

A Bechtel Power Corporation report on the Radwaste Area Ventilation System, Log BE-6344, dated October 5, 1982, addressed building negative pressure, rooms without mechanical ventilation (172) and rooms with mechanical ventilation (98). The report concluded that with doors in the proper position, seals on a number of doors and penetrations and with the addition of ventilation ducting to the two waste gas compressor rooms the HVAC system meets the FSAR described performance. During numerous tours of the radwaste building the inspector has observed that negative pressure is maintained and that negative pressure is maintained in the waste gas compressor rooms with the additional ducting which Was installed.

3 With respect to the DAW compactor the licensee's Health Physics Engineering group evaluated the compactor use and concluded that with appropriate controls (e.g. respirators required, compactor filters tested following installation, proper air flow, access control and air sampling) the compactor could be operated and exhausted to the room air. Based on observations and document review this matter is considered closed.

No violations or deviations were identified.

3. Review of Licensee Reports The inspector reviewed Licensee Event and Special Reports related tp radiation protection and chemistry matters. The review verified that reporting requirements were met, causes identified or under investigation, that corrective actions appeared appropriate and that LER forms were complete. Reports identified with an asterisk, indicate a more detailed on site review.

Docket No. 50-206 50-361 50-362 85-07-LO 84-44-LI 85-12-LO 85-08-X0 85-08-XO 85-18-L0.

85-08-X2 85-23-LO 85-21-LO 85-09-LO 85-25-LO 85-23-LO 85-10-LO 85-27-LO 85-24-LO

"*85-15-LO 85-29-LO 85-25-LO 85-32-LO 85-27-LO 85-33-LO 85-28-LO 85-36-LO *85-31-L0 85-37-LO 85-33-LO 23-29-" 1 "*85-35-L0 85-43-10 85-34-LO 85-44-LO 85-37-LO 85-48-LO 85-41-LI 85-53-LO 85-56-LO LER 50-206/85-15-LO, reported discovery of two holes in the containment/stack line to monitors R-1211 and R-1212. The licensee temporarily patched the holes and planned to replace the sample line during the current outage. The licensee agreed to evaluate the effect of the holes, which may have existed since the sphere shield construction project (1975), on reports of effluents from Unit 1. This matter will be examined during a subsequent inspection (50-206/86-02-01).

Unit 3, LER's 85-31-LO and 85-35-LO reported FHIS and CPIS actuations respectively. Followup onsite confirmed no relationships with the fuel particle problem (see report section 7).

No violations or deviations were identified.

4. Unit I Gaseous Waste System A. Audits and Appraisgls Records of audits performed by Quality Assurance (QA) were examined and discussed with the responsible QA engineers. Audit No.'

SCES-020-85, conducted March 21 to May 24, 1985, verified that procedures were in compliance with changes made to the Offsite Dose Calculation Manual (ODCM) and the Radiological Environmental Technical Specifications (RETS). The scheduled audit for 1986 had not been conducted at the time of this inspection. The review found the auditor's qualifications included four years of experience as a Health Physics technician preparing effluent release permits.

B. Changes Discussion with licensee representatives and a tour of the facilities disclosed that the gaseous waste system had not been changed with the following exceptions:

1. The cryogenics system had been retired in place.

2. A second computer based data reduction system was used to prepare monthly reports and verify release calculations.

C. Effluents The inspector reviewed the Monthly Effluent Reports for the period January 1985 to December 1985. Releases were within 10 CFR 50 Appendix I guidelines and the EPA limits expressed in 40 CFR 190.

The inspector verified by manual calculations that the beta and gamma air doses from Kr-85, Xe-131m, Xe-133m and Xe-133 as reported in a Gaseous Effluent Release Permit were correct. The inspector also verified by manual calculation the maximum organ dose from 1-131 using data from the July 1985 Plant Vent Stack Release Report.

The licensee's use of ODCM dose conversion factors was confirme'd.

The inspector discussed the gaseous effluent release process with the chemistry supervisor and a chemistry technician and verified that the proper procedure was used for sampling the waste gas decay tanks. The inspector was unable to observe the preparation of release permit since the tanks had been emptied following a the plant shutdown on November 21, 1985.

D. Air Cleaning The Unit 1 Facility Technical Specification section 3.12 Control Room Emergency Air Treatment System requires that the system be maintained operable including satisfactory execution of the'tests and analyses specified in Technical Specification 4.11 Control Room Emergency Air Treatment System. Maintenance Order 840830930, action on which was completed October 23, 1984, included necessary testing and the replacement of one leaking carbon I filter.

5 Technical Specification 4.1] requires testing once per year for standby service or after every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation. The testing was initially scheduled in October 1985 however the work order had been placed on hold while the plant was in modes 5 and 6.

The work was rescheduled for completion immediately prior to mode 4 operation.

No violations or deviations were identified.

5. Radiological Environmental Monitoring The subject program was last inspected January 23-27, 1984 (Inspection Report No. 50-206/84-04, 50-361, 362/84-05). The meteorology portion of the program was addressed in Inspection Report 50-206/83-24, 50-361/84-39 and 50-362/83-38.

A. Audits and Appraisals The audit program included both the licensee and contractor phases of the program and was conducted by both the onsite and corporate QA organizations. Reports of audits and surveillances were examined.

Audit Report No. Date Topic RDC-1-84 12/14/85 Contractor-Radiation Detection Company LFE-1-84 7/27/85 Contractor-EAL Corp. (Analytical Contractor)

LFE- 1-85 7/2/85 Contractor-EAL Corp. (Analytical Contractor)

SCES-075-85 All Tech. Spec. Units 1, 2 & 3, Land Use Census Contractors SCES-088-84 12/3/84- Units 1, 2 & 3 Tech. Spec. Report 1/30/85 Submission SCEE-9-85 10/25/85 Timely Submission of Reports SCEE-8-85 10/21- Verify Transfer.'of Functions to 11/8/85 Nuclear Services Group SCEE-6-85 10/17- Construction-Offshore Pad Removal 11/17/85 SCEE-5-85 8/12 Verify Environmental Record Retention 8/29/85 SCEE-4-85 6/28 Verify Implementation of Environmental 8/5/85 Protection Plan-Unit 2/3 SCEE-3-85 4/15 Verify Implementation Unit 1 7/17/85 Environmental Tech. Spec.

SCEE-1-85 2/27 Verify Implementation Unit 1 3/8/85 Environmental Monitoring Tech. Specs.

Surveillances were conducted of Westec Services Inc. marine sampling contractor (ENV-1210-84, 10/16/84) and of local crop sampling by the onsite environmental group (ENV-002-84, 8/2i/84).

A small number of discrepancies were identified during the audits which resulted in the issuance of Corrective Action Requests (CARs),

for which prompt and effective corrective actions were taken. The

6 most significant and still unresolved matter concerned the licensees failure to report NPDES (National Pollution Discharge Elimination System) violations to NRC pursuant to the Unit 2/3 T.S. 6

.9.3.g and Unit 1 T.S. 6 .19.2..c (now 6 . 1 6 .2.c as per Amendment 91).

The T.S.

require the licensee to provide copies of reports of violations of NPDES Permits or State certifications*(pursuant to Section 401 of the Clean Water Act) to the NRC. This failure was initially identified in connection with Units 2/3 by Audit SCEE-4-85 and CAR GO-G-107 was issued. Subsequently Audit SCES-075-85 identified the failure in connection with Unit I and the previously issued CAR was amended to address all three Units.

At the time of the inspection the licensee had not resolved the response to the CAR. The failure to resolve the issue centers on the interpretation of the term violation. The NPDES permits issued by California Regional Water Quality Control Board order for San Onofre are:

Unit Order Number Permit Number Unit 1 76-21 CA 00033 Unit 2 85-11 CA 0108073 Unit 3 85-13 CA 0108181 The Permits require the annual reporting of detailed analytical results. The licensee voluntarily submits reports on a monthly basis. Some of these reports contain values which are in excess Permit levels but are not necessarily of such significance of as to be reportable to NRC in the view of SCE's Operations and Maintenance Support (O&S) organization. SCE's QA organization has viewed these reports as reportable to NRC since they represent violations of Permit levels.

The Permits also provide in section F.6. for oral notification 5 day written and a report of, "any noncompliance which may endanger health or the environment". In addition section F.7. requires notification, "as soon as it is known if there is reason believe;" that certain discharges have or may occur. to O&HS contentds that those matters properly reportable to NRC are those described in Permit sections F.6 and F.7. No events requiring reporting under sections F.6. and F.7. have occurred. The licensee's resolution of CAR GO-G-107 will be examined during a subsequent inspection (50-206, -- 36, -362/86-02-02).

B. Changes The onsite environmental monitoring representative, an Environmental Engineer, now reports administratively to the O&21S organization technically to the supervisor of the corporate Nuclear and Safety and Licensing (NS&L) group. This individual had been employed at San Onofre in this capacity since 1982 and was completing degree work for a BA in Environmental Analysis. The onsite representative was responsible for collection, packaging, shipment and record keeping of all terrestrial sampling and TLDs. All terrestrial samples were

7 shipped by Express Mail to EAL Corporation, the analytical contractor. TLDs were shipped to Radiation Detection Company.

Marine samples were collected by Westec Services Inc. formerly Lockheed Ocean Sciences Laboratory under a contract administered by NS&L. Weekly reports of samples collected, problems identified (e.g. reduced air sample volume due to pump or power failures) sent to NS&L. were The only change in sampling location since the last inspection was the San Clemente air sample location, formerly at the San Diego Gas and Electric building, which was moved to the San Clemente City Hall effective January 14, 1986. The new sample location is in the same sector at approximately the same distance from the plant. The change was required by the sale of the building at the original location.

The marine sampling program, annual census program and corporate office portion of the program will be examined during a subsequent inspection (50-206, 361 & 362/86-02-03).

C. Implementation of the Radiological Environmental Monitoring Program The Annual Radiological Environmental Operating Reports for 1983 and 1984 were reviewed. The "Mesa-E.O.F." sampling station was observed during the weekly particulate and iodine sample change. The station also included TLD's and a pressurized ion chamber. Environmental program procedures were reviewed, specifically:

Number Title Date S0123-IX-1.1 Rev. 1 Environmental Sample Collection 8/26/85 S0123-IX-1.2 Rev. I Air Sampling 8/26/85 S0123-IX-1.4 Rev. 2 Drinking Water 8/26/85 S0123-IX-1.5 Rev. 2 Sediment from Shoreline 8/26/85 (Beach Sand)

S0123-IX-1.6 Rev. 2 Local Crops 8/27/85 S0123-IX-1.8 Rev. 2 Soil Sampling 8/26/85 D. Implementation of the Meteorological Monitoring Program The licensee contracts with Dames and Moore for monthly maintenance and quarterly calibrations of meteorological equipment and data reduction of chart and data logger (digital) records. The licensee's I&C staff changes the recorder charts every two weeks.

Monthly maintenance records for the period June-December 1985 and the second and third quarterly calibrations in 1985 and the first quarterly calibration in 1986 were examined.

No violations or deviations were identified.

6. Occupational Exposure During Extended Outages - Unit 1 A. Audits and Appraisals

8 No audits specifically addressing this topic area had been conducted. Two surveillances related to this topic had been conducted:

HP-007-86, Bioassay, Verification of Iodine Protection Factor, as applied to the use of the GMR Iodine respirator canister; and HP-034-86, Health Physics Surveillance, visual inspection of postings, containment housekeeping, availability of supplies of booties and gloves in containment and frisker operation at the equipment hatch exit. The surveillance noted the high frisker background at that location.

B. Changes The licensee had planned a reorganization of the operational H.'P.

staff to improve control of technician activities and to provide a single responsible Health Physics representative onsite at all times. Technician crews of 6-8 will be permanently assigned to a foreman. Each crew and foreman will rotate through the shift schedule. Two general foremen will be assigned one each to Units I and 2/3. The general foremen will assign crews on the basis of work load and job priority.

For the Unit 1 outage in order to maintain technician exposures ALARA, the job coverage had been changed from constant to zone coverage. Continuous health physics coverage requirements have been relaxed for some evolutions.

Individual technician exposure was to be administratively limited to 300 mrem/quarter. Cumulative technician exposure was to be'followed by the foremen on a daily basis to provide for appropriate distribution of exposure. Crew exposures were to be evenly distributed within +/- 250 mrem. Increases in the administrative limit can be approved only after justification and review by the Unit Health Physics Supervisor. This change was in response to a Health Physics Division goal to reduce exposures received by the Health Physics staff. All health physics supervisors were coordinating their efforts with the ALARA supervisor. As part of this effort the licensee had increased the use of alarming dosimeters which can be preset to alarm at various total exposures, reducing the necessity for constant coverage by technicians.

The new Health Physics building was in service replacing the old Third Point access to Unit 1. Access through Door 16 was limited to operations personnel requiring prompt access.

C. Planning and Preparation Unit I health physics representatives including the assigned Unit 1 ALARA Engineer began attending planning meetings in May 1985. In September 1985, two technicians were assigned to work with the Unit I Maintenance Schedulers in outage planning.

9 Thirty contract technicians, onsite for the Unit 3 outage and 23 Unit 2/3 technicians were used to augment the Unit I technician staff of 15 providing a total of 68 technicians for the Unit I

outage.

The staffing increase was delayed past the start of the Unit I outage since the outage began a week early as a result of the water hammer event. The contract technician staff was increased to limit the number of overtime hours worked by the staff. The health physics staff was operating three shifts using three foremen and two upgraded technicians per shift. The health physics staff reported good cooperation from various work groups in prioritizing work based on technician availability.

Special training on steam generator repairs and penetration work was planned. Due to the two unit outage, only foremen received the, penetration work training and few technicians received steam generator mock up training. However the crews that had done the Unit 3 steam generator work were available for Unit 1 and several contractor technicians had good steam generator work experience.

An additional breathing air compressor was provided which augmented the existing equipment. The compressors were able to support 6 manifolds which permitted supplied air work simultaneously on the three steam generators, penetrations, upender cavities in containment and in the fuel building and the north charging pump room.

Portable ventilation units were used during the steam generator work. A contamination control tent was utilized in the auxiliary building for the charging pump work.

D. External Exposure Control Discussions with the dosimetry staff established that no changes had occurred with respect to the program for utilization of extremity and specialized dosimetry or to station administrative exposure limits. Pocket ionization chamber (PIC)/TLD comparisons were performed by the licensee. PIC's were generally found to indicate higher exposures than TLDs but most were within 25% of the TLD indicated exposure. No problems had been identified with respect to extremity exposures. Daily reports of work groups or department exposures were provided to supervisors as well as an alphabetical listing of individual exposures.

E. Internal Exposure Control No changes in the internal exposure control program were identified.

A corporate Dosimetry Records and Archival Retrieval System (DARS) had been implemented. No concerns with respect to Unit I internal exposures were identified. Records of evaluations of internal exposures and bioassays and whole body counts will be examined during a subsequent inspection (50-206/86-02-05).

]0 F. Control of Radioactive Materials and Contamination, Surveys and Monitoring Portable survey instruments available for use were examined and found to be within the required calibration frequency.

Frisker stations were observed and noted to be set on the appropriate range.

Use of friskers by personnel exiting the Unit I containment, radwaste building and the controlled area at the health physics building were observed to be of appropriate duration thoroughness. and Records of surveys will be examined during a subsequent inspection (50-206/86-02-06).

6. Maintaining Occupational Exposures ALARA The licensee had established a station goal of less than 1000 manrem for 1986. The 1985 Unit I goal was 305.4 manrem. The approximate Unit '1 total exposure was 70 manrem prior to the outage and 96 manrem during the first month of the outage (December 1985), a total of approximately 170 manrem.

The Unit 2/3, 1985 goal was 767.6 manrem and the measured 605.5 manrem. Examination of the source of exposure exposure was to Unit I health physics personnel identified surveys as a principal contributor. As a result the frequency of routine surveys of areas not continuously occupied had been reduced. The change which, was implemented in Qctober-November 1985, had resulted in reduced personnel exposures. No changes in connection with contamination control had been observed. The largest single contributor to exposures were the surveys associated with radiation exposure permit (REP) preparation. In cooperation with the Maintenance Department only maintenance tasks to be started within two days are submitted for REP preparation. This change from the previous practice of submitting, all jobs scheduled (e.g. the January 6-12, 1986 list called for REP's for 258 jobs) was expected to result in a significant manrem reduction. Additional ALARA related topics were identified in section B. above.

The licensee had implemented an ALARA awards program providing for quarterly recognition of outstanding exposure reduction awards are based on established guidelines and include efforts. The certificates and a prize.

Significant ALARA activities noted by the inspector at Units 2/3 included:

Operation's and Management Supports development of a steam generator manway shield which provided a small opening for eddy current testing while reducing the platform exposure to approximately mrem/hour. 100 The shield also has doors which close the opening when not in use.

Robotics device "Genesis" used for ultrasonic testing and mechanical steam generator tube plugging saved an estimated 20 manrem.

II Learning through experience on the Pressurizer Spray Valve work, using the same crew where possible, the Unit 2 work resulted in 75.5 manrem of exposure. The same work on Unit 3 resulted in 57.8 manrem exposure.

No violations or deviations were identified.

7. Unit 3 Fuel Fragment (Fuel Fleas) Contamination A. Beginning on October 30, 1985, the licensee identified the existence of microscopic particulate contamination with fuel fragments subsequently dubbed "Fuel Fleas". Following the recognition of this problem, extensive surveys were conducted of the Fuel Handling Building, Radwaste Building and all levels of the Unit 3 Containment and the reactor cavity. The particles are believed by the licensee to have apparently originated during a fuel bundle reconstitution evolution performed in the Unit 3 Fuel Handling Building.

While "Fuel Fleas" were found in other areas the principal concentrations were found in the Unit 3 Fuel Handling Building and reactor cavity. The contamination in the reactor cavity was principally in the lower level near the upender. located The major portion of this activity was flushed to the radwaste system. Some of the "Fuel Fleas" were found on modesty garments.

Frisking of modesty garments at the laundry was increased to a 100% sample. The solvent and lint filters from the modesty garment dry cleaning machines were surveyed for presence of the "Fuel Fleas" with negative results.

Protective clothing used in the Unit 3 Fuel Handling Building was isolated. Access to the Fuel Handling Building was routine non-essential access on November denied for 6, 1985 so that extensive radiological surveys could be conducted.

After successful decontamination efforts the building was released for access.

Personnel who had worked in the Fuel Handling Building following the fuel reconstitution evolutions were identified and whole body counts were performed. No indications of "Fuel Flea" constituents found in the first were 80 persons counted. Extensive review of air sample data showed no evidence of "Fuel Fleas" or their constituents. Surveys established that no '"uel Fleas" were found more than one foot above the floor.

On November 21, 1985 access to the Fuel Handling Building was again restricted for decontamination. Access was limited to the decon crew and operator surveillance under continuous H.P. coverage.

Since protective clothing appeared to be a medium for the transfer of "Fuel Fleas" all protective clothing was withdrawn from use.

Protective clothing unused since before the reconstitution Unit 3 fuel work or disposable protective clothing was used to replace the withdrawn clothing.

Licensee analysis of "Fuel Fleas" identified the presence of the following fission products: Nb-95, Zr-95, Ru-103, Ru-106, Ba-140, La-140, Ce-141 and CE-144. EAL Corporation analyzed three '"Fue' Fleas" and confirmed the licensee's analysis and in addition

identified the presence of Cs-134, 137, Pm-147, 14 8m, Eu-154, Y-91, Cm-242 and Pu-238.

Because of the high beta energy (500 keV vs 90 keV for "normal" contamination) exhibited by the "Fuel Fleas" ion chamber instrument utilizing a specially modified different window thicknesses developed by the onsite H.P. was Engineering group. This instrument was used to conduct extensive surveys.

As a result of the extensive surveys program "Fuel Fleas" were found on and the routine frisking protective clothing and modesty garments of several personnel. The licensee to assess the skin dose to exposed individuals. performed evaluations The Region V staff evaluated the licensee's of skin dose assessments for methodology and results personnel exposed to the "Fuel The licensee's evaluation included Fleas".

a conservative exposure scenario, comparison of the theoretically derived spent spectrum measured by gamma pulse fuel spectrum, and the height analysis by both SCE independent laboratory, and the final and an limiting radionuclides based estimation of activity of the on licensee assumptions. We find these studies, considerations and assumptions to be acceptable.

assumption being that the "Fuel The key Fleas" were in direct contact the skin. with The basis of acceptability was the comparison of the licensee's methodology of evaluation of skin dose, using Healy's model against other models also acceptable (1),

report '"ose Calculations for to the staff. In the draft Contamination of the Skin Including the Computer Code Varskin,"

NUREG-4418, the authors introduce computer code, Varskin, which a calculates dose to the skin by emitting radionuclide, from a beta point and disc sources. They use Berger's (2) data of energy distribution around point sources water from which they compute in skin dose as a function of distance for a point or disc source (skin thickness), of any given strength and time of exposure. The model and data of Spangler was also used by the staff as and Willis (3) an alternative method (Loevingers equations (4)) for skin evaluation.

Using the data, provided to the staff by the licensee, of one exposed individuals, the following of the results were tabulated, as shown, for two of the radionuclides identified in the inventory products which comprised the of fission "Fuel Flea".

Dose (mrad for 2.2 hr exposure)

Isotope uCi/cm2 SONGS VARSKIN SPANGLER 91 Y 1.98x10 2 405 140 Ba 337 330 8.25x10 16 12 14 It is noted that the Healy model, used by the licensee, conservative dose estimate as provides a compared to the Varskin computer and the Spangler model. code

13 Based on the conservative model used by the licensee the skin dose to individuals exposed to determine to "Fuel Fleas", and the fact that the dose estimate for all the radionuclides found in-the "fuel flea" provides a total dose of 1517 mrem to the exposed individual which represents 20% of permissible skin dose, the staff finds the SCE methodology for skin dose evaluation to be acceptable.

(1) Surface Contamination - Decision Levels - LA-4558-MS - J. W. Healy (2) M. J. Berger, MIRD #8, J. Nucl. Med.

(3) G. W. Spangler, C. A. Willis "Permissible 1971 Contamination Levels" Proceeding of a Symposium held at Gatlenburg, Tennessee June 1984 pg 151-158)

(4) Describe Radioisotope Sources - R.

Loevinger, etal "Radiation Dosimetry" Hine and Brownell pp. 711-715.

The final licensee actions and effectiveness of the decontamination will be examined in a subsequent inspection (50-362/86-02-04)

No violations or deviations were identified.

8. Tours Tours were conducted during the inspection of the protected areas of all three units, the Unit I containment, radwaste building, backyard, chemistry laboratory, and the health physics building. Confirmatory radiation surveys were performed with an ion chamber survey instrument, NRC-015844, due for calibration February 18, 1986. No discrepancies in posting were identified. In addition the recently completed Control Building, with office space Materials on the second floor and decontamination facilities on the first floor, and the laundry - change room facilities on 65.5-70 elev. Units 2/3 and Multipurpose Handling Facility which were under construction were toured.

No violations or deviations were identified.

9. Followup on IE Information Notices The inspector verified receipt, review for applicability and initiation or completion of action, if required, with respect to IE Information Notices Nos. 85-42, 85-42 Rev. 1, 85-81, 85-87 and 85-92.

No violations or deviations were identified.

10. Exit Interview The scope and findings of the inspection individuals denoted in report were discussed with the section 1. The licensee was informed no violations or deviations were that identified.

C. -- ;m

• I9OVSEAR 13 S.

5:08 AD1 2-QL SONGS 1. 2 and 3 S. NEHO ZZ March 12. 1986

-g 11 HAROLD B. RAY

SUBJECT:

NRC Inspection Report No. C.,)

50-206/86-02, 50-361/86-02 and 50-362/86-02 San Onofre Nuclear Generating Station, Units 1, 2!and 3 Attached for is a copy of NRC letter your information and appropriate dated March 7, 1986, transmittingaction subject Inspection Report covering the the Units 1, 2 and 3 Radiological Program routine inspection of conducted January 13-17, 1986 and February 3-7, 1986.

Areas inspected included: licensee action on previous inspection findings, review of licensee systems, radiological environmental monitoring, reports, gaseous waste exposure during extended outages, Unit occupational contamination, facility tours and followup 3 fuel fragment on Information Notices.

No violations of NRC requirements were within the scope of the inspection. identified If you have any questions, please contact me.

6YK-MCURRAN DCallahan: 8 933Q/sit Attachment cc: Kenneth P. Baskin K. A. Slagle F. P. Eller. Jr.

M. 0. Medford D. P. Breig R. M. Rosenblum D. H. Peacor M. P. Short W. G. Zintl D. A. Herbst H. E. Morgan D. F. Pilmer K. G. Grothues R. W. Krieger J. K. Yann E. N. Cramer M. A. Wharton D. B. Schone H. S. Leasure J. T. Reilly R. N. Schweinberg J. A. Beoletto D. E. Shull D. E. Nunn L. Mayweather/SOCR B. Katz QA File P. J. Knapp J. J. Wambold CDM Center H. L. Chun

REFERENCE E February 3, 1982 Director, Office of Nuclear Reactor Regulation Attention: Mr. Frank Miraglia, 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 ? and 3 On January 28, 1982, a meeting was held at the NRC offices in Bethesda, Maryland. The purpose of the meeting was to discuss the implementation program for radiation monitors for San Onofre Nuclear Generating Station, Units 2 and 3.

The implementation program has two main objectives. The first is to provide radiation monitors for which the calibration is consistent with the latest state of the art criteria on the most expeditious schedule possible.

The second objective is to ensure consistency between the schedule for bringing the radiation monitors into full compliance with the technical specifications and the stage in the initial plant startup at which they are functionally required. To achieve these objectives we have developed a phased approach.

In accordance with agreements reached in the meeting, enclosed for your use are seven (7) copies (NRC Mail Code B028) of the following material: : Specific Technical Specification pages changed to provide schedule relief requested to allow sufficient time for enhanced calibration of radiation monitors. : Tabular presentation summarizing for each radiation monitor, the schedule relief requested, the reason the schedule relief is required and justification for the schedule relief. : Justification for schedule relief on installation of proportional samplers.

Mr. Frank Miraglia -2 : Discussion of present containment purge sampling provisions.

If you have any questions concerning these matters, please call me.

Very truly yours, P. Baskin t.' nager of Nuclear Engineering, Safety, and Licensing DLCox:3336 Enclosures cc: F. J. Wenslawski-Region V bcc: (See attached sheet)

ENCLOSURE 4 DISCUSSION OF CONTAINMENT PURGE SAMPLING PRESENT PROVISION Two NMC gaseous radiation monitors, RE-7804-1 and RE7807-2, (FSAR-11.5.2.1.4.5) presently monitor containment airborne activity. Monitor RE-7804-1 samples the containment atmosphere at approximately elevation 90 feet (same vicinity as the mini-purge exhaust) and moniter RE-7807-2 samples at approximately elevation 35 feet. Extensive mixing of the containment atmosphere by the normal HVAC units ensures that either sample location is representative of the entire containment atmosphere, and therefore considered to be representative of the containment purge effluent stream. In particular, either sample location will be representative of the large purge-system effluent stream, due to the multiple distribution lines of this system within containment. These monitors provide the capability for Iodine, particulate and gas grab sampling. A correction factor will be applied to the sample analysis to account for sample line deposition. Flow indication is provided on the monitor. Based on the above, these monitors will be used to obtain composite samples of the purge stream as required by Technical Speci ficati ons.

REFERENCE F NUREG-0712 Supplement No. 5 Safety Evaluation Report related to the operation of San Onofre Nuclear Generating Station, Units 2 and 3 Docket Nos. 50-361 and 50-362 Southern California Edison Company, et al.

U.S. Nuclear Regulatory Commission

.Office of Nuclear Reactor Regulation February 1982

2/16/82 TABLE OF CONTENTS PAGE INTRODUCTION AND GENERAL DISCUSSION ..................... 1-1 1.1 Introduction ....................................... 1-1 1.7 Summary of Outstanding Issues ...................... 1-1 1.9 License Conditions ................................. . 1-2 1.12 Status of San Onofre 2 Construction and Preoperational Testing ............................. 1-3 3 DESIGN CRITERIA-STRUCTURES, COMPONENTS, EQUIPMENT AND SYSTEMS ................................................. 3-1 3.7 Seismic Design ..................................... 3-1 3.7.4 Seismic Design Verification Program ......... 3-1 3.8 Design of Category I Structures .................... 3-12 3.8.1 Concrete Containment ........................ 3-12 5 REACTOR COOLANT SYSTEM AND CONNECTED SYSTEMS ............ 5-1 5.4 Component and Subsystem Design ..................... 5-1 5.4.3 Shutdown Cooling System (Residual Heat Removal System) ............................. 5-1 6 ENGINEERED SAFETY FEATURES .............................. 6-1 6.4 Control Room Habitability Systems .................. 6-1 7 INSTRUMENTATION AND CONTROLS ............................ 7-1 7.2 Reactor Protection System .......................... 7-1 7.2.4 Bypass of a Plant Protection System Trip Channel ..................................... 7-1 7.5 Safety-Related Display Instrumentation ............. 7-2 7.5.1 Post-Accident Monitoring Instrumentation .... 7-2 9 AUXILIARY SYSTEMS ....................................... 9-1 9.5 Other Auxiliary Systems ............................ 9-1 9.5.1 Fire Protection System ...................... 9-1 San Onofre SSER #5 iii

TABLE OF CONTENTS (continued)

PAGE 11 RADIOACTIVE WASTE SYSTEM ................................ 11-1 11.1 Summary Description ............................... 11-I 11.3 Process and Effluent Monitoring Systems ........... 11-1 22 TMI-2 REQUIREMENTS ..................................... 22-1 22.2 Discussion of Requirements ........................ 22-1 I.A.1.3 Shift Manning ......................... 22-1 I.C.I Guidance for the Evaluation and Development of Procedures for Accidents and Transients .............. 22-2 II.E.3.1 Emergency Power Supply for Pressurizer Heaters ............................... 22-3 II.K.2.17 Potential for Voiding in the Reactor Coolant System During Transients ...... 22-3 II.K.3.30 Revised Small-Break LOCA Methods to Show Compliance with 10 CFR 50, Appendix K............................ 22-4 III.A.2 Improved Licensee Emergency Prepared ness - Long Term ...................... 22-4 APPENDICES A CONTINUATION OF CHRONOLOGY ................... A-1 B ERRATA TO SER AND SER SUPPLEMENTS ............ B-1 C PRINCIPAL STAFF REVIEWERS .................... C-1 San Onofre SSER #5 iv

1 INTRODUCTION AND GENERAL DISCUSSION 1.1 Introduction On December 31, 1980, the Nuclear Regulatory Commission (NRC) staff issued a partial Safety Evaluation Report (SER) covering the geology and seismology aspects of the San Onofre Nuclear Generating Station Units 2 and 3 (SONGS 2 and 3, or San Onofre 2 and 3). On February 6, 1981, the staff issued a complete SER covering all non-TMI-related aspects of our safety review of San Onofre 2 and 3, including, for convenience, the previously issued geology and seismology sections. On February 25, 1981, the staff issued Supplement No. 1 to the SER which addressed the TMI-related aspects of our safety review. On May 8, 1981, the staff issued Supplement No. 2 to the SER, which addressed a number of the open items identified in the SER and in Supplement No. 1 to the SER. On September 16, 1981, the staff issued Supplement No. 3 to the SER, in which we updated the status of our review with regard to certain of the items that were left unresolved in Supplement No. 2 to the SER. On January 22, 1982, the staff issued Supplement No. 4 to the SER in which we addressed the open items identi fied in the SER and previous supplements, as well as several TMI-related items, for which the applicants had requested relief from the dated requirements of NUREG-0737.

In this supplement to the SER, we address several items that have come to light since the previous supplement was issued, including an additional applicant request for relief from certain dated requirements of NUREG-0737.

The items addressed in this report are covered in sections having the same number and title as the section of the SER or SER Supplement in which they were previously discussed. Appendix A to this report is a continuation of the chronology of the radiological review of San Onofre 2 and 3. Appendix B con tains errata to the SER and previous SER supplements. Appendix C is a list of the principal NRC staff reviewers who contributed to this supplement. The NRC project manager for San Onofre 2 and 3 is Mr. Harry Rood. Mr. Rood may be contacted by writing to the Division of Licensing, U.S. Nuclear Regulatory Commission, Washington, D.C., 20555.

1.7 Summary of Outstanding Issues In its Partial Initial Decision on San Onofre 2 and 3 of January 11, 1982, the Atomic Safety and Licensing Board authorized issuance of a license permitting "the loading of fuel and low power testing (up to 5 percent of rated power) for Unit 2 of the San Onofre Nuclear Generating Station."

The Board's Order was subject to the following condition: "that the Emergency Plan for Units 2 and 3 will be in effect prior to the first fuel loading activities, including complete implementing procedures and accomplishment of all required training. Satisfaction of this condition shall be evidenced by an NRC inspection and report to the Board. If any deficiencies are found, the report shall include an assessment of their significance to the activities authorized by this Order."

San Onofre SSER Supplement #5 1-1

By letter dated February 12, 1982, the NRC staff submitted the required report to the Board, in satisfaction of the condition in the Board's Order.

At this time there are no outstanding issues that must be resolved prior to issuance of an operating license for San Onofre 2 authorizing fuel loading and operation at power levels up to five percent of full power.

1.9 License Conditions In the SER and previous SER supplements, a number of potential license con ditions were discussed. By letter dated February 3, 1982, the applicants have identified three areas where plant modifications have been completed, thereby eliminating the need for a license condition. These areas are:

(1) Control room design review (NUREG-0737 Item I.D.1). Items 1.0, 2.0, and 3.0 have been completed. See Section 22.2 (I.D.1) of Supplement 1 to the SER.

(2) Additional accident monitoring instrumentation (NUREG-0737 Item II.F.1, Attachment 6). One channel of the containment atmosphere hydrogen concentration monitor has been attached to a recorder. See Section 22.2 (II.F.1) of Supplement 1 to the SER.

(3) Upgraded emergency preparedness (NUREG-0737 Item III.A.1.1). The appli cants have completed installation and operational testing of the 10-mile emergency planning zone early warning system. See Section 22.2 (III.A.1.1) of Supplement No. 1 to the SER.

Since the last SER supplement was issued, several new issues have arisen, and new information has been developed for several issues previously discussed in the SER and its supplements, for which a license condition may be desirable to ensure that staff requirements are met during plant operation. These are listed below. Some of these items must be completed by a fixed date, and some are tied to specific stages of operation, such as exceeding 5 percent of full power.

(1) Inspection requirements. Section 1.12.

(2) Design verification program final report. Section 3.7.4.

(3) Containment tendon surveillance and re-tensioning. Section 3.8.1.

(4) Control room pressurization system modifications. Section 6.4.

(5) Post-accident monitoring instrumentation. Section 7.5.1.

(6) Emergency lighting system. Section 9.5.1.7.

(7) Review of differences from Section 9.5.1 of NUREG-0800. Section 9.5.1.11.

(8) Process control program. Section 11.1.

(9) Purge stack monitors. Section 11.3.

San Onofre SSER Supplement #5 1-2

(10) Shift manning. Section 22.2 (I.A.1.3).

(11) Emergency procedures. Section 22.2 (I.C.1).

(12) Pressurizer heater reset procedures. Section 22.2 (II.E.3.1).

(13) Analysis of voiding in reactor coolant system. Section 22.2 (II.K.2.17).

(14) Revised small-break LOCA methods. Section 22.2 (II.K.3.30).

(15) Improved emergency support facilities. Section 22.2 (III.A.2).

1.12 Status of San Onofre 2 Construction and Preoperational Testing By letter dated February 9, 1982, SCE stated with regard to San Onofre 2 that "plant design and construction are in accordance with the application" and "the unit is ready to enter the fuel loading and low power testing phase of the start-up program."

In addition, the NRC staff has inspected San Onofre 2 and has determined that construction and preoperational testing of the facility have been completed in substantial agreement with docketed commitments and regulatory requirements, with the exceptions noted below. No additional items resulted from the inspection effort that would preclude issuance of an operating license to permit facility operation up to five (5) percent of full power. The items given below will be included in the San Onofre 2 operating license as conditions.

(1) Fire Protection System Prior to fuel loading, the Southern California Edison Company (SCE) shall complete inspection of all Unit 2 and Common Area fire seals, and shall repair deficient seals or implement compensatory measures as defined in the Technical Specifications.

(2) Post-accident Sampling Prior to exceeding five (5) percent power, the post-accident sampling system shall be operable and the post-accident sampling program shall be fully implemented.

(3) Surveillance Program Prior to entering any operational mode for the first time, including initial fuel loading, SCE shall:

a. Have completed a review of the surveillance procedures applicable to the change of mode, and determined that the procedures demonstrate the operability of the required systems with respect to all acceptance criteria defined in the Technical Specifications.

San Onofre SSER Supplement #5 1-3

b. Have dispatched written certification to the NRC Regional Administrator, Region V, that the actions defined in a, above, have been completed for the mode or modes to be entered.

(4) Laboratory Instrumentation Prior to initial entry into operating Mode 2, the laboratory instrumenta tion described in Sections 11.5.2.2.2 and 12.5.2.2.1 of the Final Safety Analysis Report shall be calibrated and shall be capable of analyzing sample types and geometries necessary to support facility operation. In addition, at that time there shall also be approved, written procedures governing laboratory operations and analyses.

San Onofre SSER Supplement #5 1-4

11 RADIOACTIVE WASTE SYSTEM 11.1 Summary Description of the UF radwaste solidi SER, repeated mention was made 3.

In Section 11 of the at that time, planned for use at San Onofre 2 and fication system that was, applicants stated that the staff review of Section 11 was complete, the used for solidification.

After isolated and will not be the UF system will be totally a Chem. Nuclear Inc. solidification process, Until a new system is installed, system.

4 7 2 , will be used, with cement as the solidifcation per NUREG-0 for NRC staff review control program for this system was submitted and approved The process Until the staff has reviewed the facility.

dated January 29, 1982. from by letter shipment of "wet" solid waste the program, we will prohibit San Onofre 2 operating license.

be accomplished by a condition in the This will Monitoring System 11.3 Process and Effluent the containment committed to monitor and sample Onofre 2 and 3.

In the FSAR the applicants at San separate release pathway purge exhaust, which is a 3, 1982, the applicants propose to utilize by letter dated February However, provide a monitoring monitoring system rather than the containment atmosphere purge lines.

system directly on the concluded that the applicants' submittal, we have the containment Based on our review of the and sample the effluent via proposed capability to monitor monitoring provide the capability for continuouspurge stack for purge should be enhanced to the purge exhaust directly from and sampling of the containment purge systems. Consequently, we will the low and high volume containment license to require this capability after condition the San Onofre 2 operating outage..

the first refueling containment the applicants propose to use either of the Until that time, sampling media monitors 2RT-7804-1 or 2RT-7807-2 and the associatedUnit 2. We find airborne sampling the purge exhaust of for continuous monitoring and to startup acceptable until initial criticality; thereafter, prior use the this is to outage, the applicants' proposal following the first refueling is acceptable for monitor 2RT-7804-1 for the above mentioned purpose airborne the following reasons:

purge to the environment via the containment (1) No release of radioactivity initial criticality, since there will be no system is expected prior to criticality. In in the fuel prior to initial buildup of fission products accident during initial fuel loading, the unlikely event of a criticality isolated.

the containment will be units is mixing of the containment atmosphere by the normal HVAC Extensive representa (2) containment atmosphere is somewhat expected to ensure that the during the high volume purging.

tive of the effluent stream 11-1 San Onofre SSER #5

of (3) Technical specifications for plant operation will preclude operation the low volume purge for more than 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> a year. Since the airborne monitor RT-7804-1 and the associated sampling media are in the vicinity of the low volume purge intake, the containment atmosphere will be representative of the effluent stream during the low volume purging.

San Onofre SSER #5 11-2

APPENDIX A CONTINUATION OF CHRONOLOGY OF RADIOLOGICAL REVIEW January 13, 1982 Letter from applicants providing information on instrumentation for inadequate core cooling January 14, 1982 Letter from applicants concerning design verification program by General Atomics.

January 15, 1982 Letter from applicants transmitting several Potential Finding Reports January 18, 1982 Letter from applicants regarding instrumentation for detection of inadequate core cooling.

January 18, 1982 Letter from applicants transmitting two Potential Finding Reports January 18, 1982 Letter from applicants concerning effects of input voltage faults on plant protection system matrix relay circuit.

January 19, 1982 Letter from applicants forwarding additional Potential Finding Reports.

January 20, 1982 Letter from applicants transmitting additional Potential Finding Reports.

January 21, 1982 Letter from applicants transmitting additional Potential Finding Reports.

January 22, 1982 Letter from applicants forwarding General Atomics letter regarding its fiscal independence.

January 22, 1982 Issuance of Supplement No. 4 to Safety Evaluation Report.

January 22, 1982 Letter from applicants transmitting a Potential Finding Report.

January 22, 1982 Letter from applicants transmitting the following (proprietary and nonproprietary) reports:

(1) "CETOP-D Code Structure and Modeling Methods for San Onofre Nuclear Generating Station Units 2 and 3, "CEN-160(S), Rev. 1 (2) "Response to Questions on Documents Supporting SONGS 2 License Submittal," CEN-184(S), Rev. 2 San Onofre SSER #5 A-1

(3) "CPC/CEAC System Phase I Software Verification Test Report," 176(S), Rev. 01 (4) "CPC/CEAC System Phase II Software Verification Test Report," CEN-173(S), Rev. 02.

January 25, 1982 Letter from applicants transmitting Revision 4 to Security Plan.

January 25, 1982 Letter from applicants forwarding "Interim Report -

Independent Verification of San Onofre Nuclear Generating Station Units 2 & 3 Seismic Design and Quality Assurance Program Effectiveness".

January 25, 1982 Letter from applicants transmitting additional Potential Finding Reports.

January 26, 1982 Letter from applicants transmitting a Potential Finding Report.

January 26, 1982 Letter from applicants transmitting additional potential Finding Reports.

January 27, 1982 Letter from applicants concerning Items I.C.1 and II.K.2.17 of NUREG-0737.

January 27, 1982 Letter from applicants advising of intent to install fixed emergency lighting in certain areas prior to exceeding 5% power.

January 28, 1982 Meeting with applicants to discuss radiological technical specifications.

January 28, 1982 Meeting with applicants to discuss interim report on design verification program.

January 28, 1982 Letter from applicants forwarding recent meeting.

handouts and associated changes in control room design.

January 29, 1982 Letter from applicants transmitting revised responses to staff Question 222.44 concerning effects of control system failures and revised FSAR information concerning the shutdown cooling system and related operating procedures.

January 29, 1982 Letter from applicants forwarding several Potential Finding Reports.

January 29, 1982 Letter from applicants transmitting "CNSI Cement Solidification System" Document No. 4313-01354-01-NP.

January 29, 1982 Letter from applicants providing supplemental information to January 18, 1982 letter on matrix relay circuit.

San Onofre SSER #5 A-2

February 1, 1982 Letter from applicants transmitting request for extension of construction completion date for Unit 2 to April 2, 1982.

February 1, 1982 Letter from applicants advising that future Preliminary Finding Reports on seismic design will be transmitted to NRC after they are fully processed by General Atomics.

February 3, 1982 Letter from applicants forwarding documents related to implementation program for radiation monitors.

February 3, 1982 Letter from appplicants advising of compliance with potential license conditions in Safety Evaluation Report and revised Appendix E to 10 CFR Part 50.

February 4, 1982 Letter from applicants forwarding several additional Potential Finding Reports.

February 5, 1982 Letter from applicants forwarding several additional Potential Finding Reports.

February 8, 1982 Board Notification - NRR Draft SER on ACRS concerns Regarding System 80 Feed and Bleed Capability.

February 9, 1982 Meeting with applicants to discuss disposition of potential findings on GA design verification program.

February 11, 1982 Letter from applicants forwarding letter dated February 10, 1982 from General Atomic summarizing current status of design verification program.

February 14, 1982 Letter from applicants forwarding letter dated February 14, 1982 from General Atomic documenting state ments made in telephone discussions and additional review work.

San Onofre SSER #5 A-3

REFERENCE G ADi2 S023 NRC March 11, 1991 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:

Subject:

Docket Nos. 50-361 and 50-362 Fuel Assembly Shoulder Gap Adequacy San Onofre Nuclear Generating Station Units 2 and 3 This letter is a request for the NRC to concur that the San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 fuel element assembly (FEA) shoulder gap is adequate for the design life of the fuel, and to close the San Cnofre Unit 3 License Condition 2.C(23). References are listed in Enclosure 1. The License Condition is as follows:

2.C(23) Fuel Assembly Shoulder Gap Clearance (SCE letter of July 25. 1983)

Prior to entering Startup (Mcde 2) after each refueling, SCE shall either provide a report that demonstrates that the existing fuel element assembly (FEA) has sufficient available shoulder gap clearance for at least the next cycle of operation, or identify to the NRC and implement a modified FEA design that has adequate shoulder gap clearance for at least the next cycle of operation. The commitment will apply until the NRC concurs that the shoulder gap clearance provided is adequate for the design life of the fuel.

The review of the fuel mechanical design, including shoulder gap, is an essential element of each reload at San Onofre to determine if an unreviewed safety question exists. Considering the satisfactory results of the first five cycles, Southern California Edison (SCE) concludes there is sufficient information and experience to support closing Unit 3 License Condition 2.C(23) for Cycle 6 and subsequent cycles while relying on the standard reload process to ensure an adequate fuel shoulder gap.

The basis for this conclusion is discussed below.

Document Control Desk Background Information FEA shoulder gaps change with residence time in the reactor due to differential growth between the fuel rods and the fuel assembly guide tubes. Shoulder gap measurements taken during the first refueling outage at Combustion Engineering's (C-E) first nuclear plant (Arkansas Power and Light's ANO-2, Docket No. 50 368) using the 16X16 fuel design rsvealed shoulder gaps to be less than those predicted. As a result, mechanical mcdifications (guide tube shims) were made to selected ANO-2 Batch C fuel assemblies to ensure adequate shoulder gaps would exist for continued operation of those assemblies.

The findings at ANO-2 resulted in the NRC imposing a license condition, regarding shoulder gap adequacy, to the operating licenses of C-E plants employing the 16X16 fuel design.

To evaluate the acceptability of San Onofre Units 2 and 3 fuel operation through Cycle 3 without making mechanical modifications to the FEAs, shoulder gaps were inspected and measurements were taken on selected Unit 2 FEAs at the end of Cycle 1 (4 Batch B and 19 Batch C FEAs) and the end of Cycle 2 (2 Batch B and 13 Batch C FEAs). At Units 2 and 3, the initial fuel loading for the first operating cycle consisted of Batches A, B, and C. Both Batches B and C were used in the second operating cycle, and Batch C was also used in the third operating cycle. The shoulder gap data from these inspections and the analysis performed are summarized in References 1 and 2. The FEAs inspected and analyzed were primarily Batch C because Batch C assemblies would

1) experience the greatest differential growth and, 2) for Cycle 3, be the most limiting fuel type with the smallest initial shoulder gap (1.332 inches vs. 2.100 and 2.382 inches for the reload batches). From the results of the analysis, SCE concluded that the original core fuel design provided adequate shoulder gaps for burnups in excess of the peak Batch C discharge burnups at the end of Cycle 3 (44,000 Megawatt Days per Metric Ton), and, therefore, mechanical modifications were not required.

Current Evaluation Technique As stated in the SONGS Reload Analysis Reports, the evaluation technique for predicting shoulder gap clearance during these cycles employs the limiting fuel rod growth rate from the ANO-2 Batch C fuel and a conservative estimate of guide tube growth.

This conservative technique, which was approved by the NRC through References 3 and 4, and the much larger initial shoulder gaps of the modified fuel design for reload batches provided the basis for demonstrating that the Units 2 and 3 fuel assemblies contain adequate shoulder gaps through Cycles 4 and 5 operation

Document Control Desk (see References 5 and 6). This conservative evaluation technique will continue to be used to verify the shoulder gap adequacy of operating fuel prior to the start of each operating cycle.

As shown in Table 1, the fuel design has been modified to significantly increase the shoulder gap clearance of the reload batches. This fuel design mcdification, which provides 1.050 inches more shoulder gap clearance (2.382 inches) than the shoulder gap clearance (1.332 inches) of the initial fuel loads, ensures that the shoulder gaps are adequate for Cycle 6 and future cycles.

TIBLE 1 Comparison of Shoulder Gaps for SONGS Fuel Fuel Ini&ial Shoulder Gaps (in)

Design Unit 2 Unit 3 Batch A 1.332 1.332 Batch B 1.332 1.332 Batch C 1.332 1.332 Batch D 2.100 2.100 Batch E 2.100 2.100 Batch F 2.100 2.382 Batch G 2.382 2.382 Later Batches 2.382 2.382 We plan to continue designing fuel reload batches with an initial shoulder gap of 2.382 inches (identical to Batch G reload for Unit 2 and Batch F reload for Unit 3). Any future design change to this initial shoulder gap would be evaluated using the NRC approved analysis technique, as part of the reload process, to ensure the adequacy of the shoulder gap clearance.

Summary Unit 3 License Condition 2.C(23), regarding shoulder gap adequacy in 16X16 fuel design, was a result of observations at ANO-2 where shoulder gaps of Batch C fuel assemblies were found to be less than predicted.. Results of fuel inspections, measurements, and analyses performed at the end of Cycles 1 and 2 on selected SONGS Unit 2 FEAs verified the adequacy of the shoulder gaps through Cycle 3 operation. The reload process at SONGS, which employs the NRC approved technique discussed aboie and the larger initial shoulder gaps of the modified fuel design for reload batches, verified the adequacy of the shoulder gaps for Cycles 4 and 5 operation.

Document Control Desk The modified fuel design with initial shoulder gap clearance of 2.382 inches will continue to be used in Cycle 6 and future cycles. Current fuel management plans for Cycle 6 and subsequent cycles predict fuel discharge burnups to be less than or equal to Cycle 5 burnups. Therefore, shoulder gap clearance is determined to be adequate for Cycle 6 and beyond. Nevertheless, SCE shall continue to evaluate the adequacy of the shoulder gap as part of each SONGS Units 2 and 3 Reload Analysis Report.

Based on the acceptable shoulder gap analysis results for the first five cycles, SCE concludes there is sufficient information and conservatism to maintain an adequate shoulder gap for fuel rod design lifetime. By this submittal, SCE requests your concurrence that the shoulder gap provided is adequate for the design life of the fuel and closure of Unit 3 License Condition 2.C(23).

If you would like additional information on this subject, please let me know.

Very truly yours, R. M. Rosenblum Manager of Nuclear Regulatory Affairs LPC\GAP. ERS Enclosure cc: J. B. Martin, Regional Administrator, NRC Region V C. W. Caldwell, NRC Senior Resident Inspector, Units 1, 2, and 3

REFERENCE H RECEIVE6 UNITED STATES NUCLEAR REGULATORY COMMISSION APR 0 11991 WASHINGTON. D.C. 205M NIICUEAR LICENSING March 26, 1991 Docket Nos. 50-361 and 50-362 Mr. Harold B. Ray Mr. Gary D. Cotton Senior Vice President Senior Vice President Southern California Edison Co. Engineering and Operations Irvine Operations Center San Diego Gas & Electric Co.

23 Parker Street 101 Ash Street Irvine, California 92718 San Diego, California 92112 Gentlemen:

SUBJECT:

FUEL ELEMENT ASSEMBLY SHOULDER GAP ADEQUACY (TAC NOS. 79937 AND 79926)

By letter dated March 11, 1991, you requested staff concurrence that San Onofre Nuclear Generating Station, Unit Nos. 2 and 3, fuel element assently shoulder gap is adequate for the design life of the fuel, and to close the San Onofre Unit 3 License Condition 2.C(23). The San Onofre Unit 3 license condition states:

Prior to entering Startup (Mode 2) after each refueling, SCE shall either provide a report that demonstrates that the existing fuel element assembly (FEA) has sufficient available shoulder gap clearance for at least the next cycle of operation, or identify to the NRC and implement a modified FEA design that has adequate shoulder gap clearance for at least the next cycle of operation. The commitment will apply until the NRC concurs that the shoulder gap clearance provided is adequate for the design life of the fuel.

In your letter, you state that the use of a modified 16X16 fuel design with an FEA shoulder gap clearance of 2.382 inches (vs. 1.332 inches initially) will continue to be used in Cycle 6 and future cycles, with each additional cycle having fuel discharge burnups less than or equal to Cycle 5 fuel discharge burnups. Further, you determined that the FEA shoulder gap analysis results were acceptable for the first five cycles of operation for both units and you will continue to evaluate the adequacy of the FEA shoulder gap as a part of your reload analysis.

Messrs. Ray and Cotton Based upon this information, the staff clearance provided is concurs that the FEA shoulder gap the requirements of theadequate for the design life San Onofre Unit 3 License of the fuel. Therefore, Condition 2.C(23) have been met.

Sincerely, Lawrence E. Kokajko, Project Project Directorate V Manager Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation cc: See next page II 1

San Onofre Nuclear Generating Messrs. Ray and Cotton Station, Unit Nos. 2 and 3 Southern California Edison Company cc: Mr. Richard J. Kosiba, Project Manager James A. Beoletto, Esq. Bechtel Power Corporation Southern California Edison Company 12440 E. Imperial Highway Irvine Operations Center Norwalk, California 90650 23 Parker Street Irvine, California 92718 Mr. Robert G. Lacy Manager, Nuclear Department Chairman, Board of Supervisors San Diego Gas & Electric Company County of San Diego P. 0. Box 1831 1600 Pacific Highway, Room 335 San Diego, California 92112 San Diego, California 92101 Mr. John Hickman Alan R. Watts, Esq. Senior Health Physicist Rourke & Woodruff Environmental Radioactive Mgmt. Unit 701 S. Parker St. No. 7000 Environmental Management Branch Orange, California 92668-4702 State Department of Health Services 714 P Street, Room 616 Mr. Sherwin Harris Sacramento, California 95814 Resource Project Manager Public Utilities Department Resident Inspector, San Onofre NPS City of Riverside c/o U.S. Nuclear Regulatory Commission 3900 Main Street Post Office Box 4329 Riverside, California 92522 San Clemente, California 92672 Mr. Charles B. Brinkman Mayor Combustion Engineering, Inc. City of San Clemente 12300 Twinbrook Parkway, Suite 330 100 Avenida Presidio Rockville, Maryland 20852 San Clemente, California 92672 Regional Administrator, Region V Mr. Phil Johnson U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Region V Walnut Creek, California 94596 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 Mr. Don J. Womeldorf Chief, Environmental Management Branch California Department of Health Services 714 P Street, Room 616 Sacramento, California 95814 (13)

REFERENCE I May 1, 1985 AOl2 S023 Director, Office of Nuclear Reactor Regulation Attention: George W. Knighton, Branch Chief Licensing Branch No. 3 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:

Subject:

Docket Nos. 50-206, 50-361 and 50-362 San Onafre Nuclear Generating Station Units 1, 2 and 3 The current Process Control Program (PCP) for San Onofre Nuclear Generating Station (SONGS) uses Chem-Nuclear, Inc. as the vendor of wet radwaste solidification services. NRC interim approval of the current SONGS PCP using Chem-Nuclear, Inc. was granted by NRC letters dated December 27, 1984 for Unit 1 and April 24, 1984 for Units 2 and 3. The Chem-tfuclear contract with Southern California Edison Company (SCE) expired on April 1, 1985. SCE replaced Chem-Nuclear, Inc. with Nuclear Packaging (NuPac), Inc. as the vendor of wet radwaste treatment services at SONGS.

NuPac's topical report, TP-02-NP, which addresses their dewatering system was submitted for NRC review in August 1984. NuPac will dewater wet radwaste at SONGS for shipment In high integrity containers in accordance with this topical report. SONGS currently has interim approval from the State of Washington for use of high integrity containers. SCE understands that review of the NuPac topical report has progressed to the point where interim, if not final approval of the dewatering system may be granted. SCE therefore requests NRC approval for the use by SCE of the NuPac dewatering system as described In the NuPac topical report.

It is SCE's intention to commence processing of wet radwaste using the NuPac dewatering system in June 1985. Therefore, approval of the use of the NuPac process at SONGS is requested by June 1, 1985.

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

Very truly yours, M. 0. Medford Manager, Nuclear Licensing PS:3939F cc: Mr. J. A. Zwolinski, Branch Chief, Operating Reactors Branch No. 5 Mr. W. A. Paulson, NRR Project Manager, San Onofre Unit 1 Mr. H. Rood, NRC (to be opened by addressee only)

Mr. F. R. Huey, Senior Resident Inspector, SONGS Mr. J. B. Martin, Regional Administrator, NRC Region V bcc: (See attached sheet)

REFERENCE J UNITED STATES C-A REG%,

• NUCLEAR REGULATORY COMMISSION WASHINGTON. 0. C. 20555 Docket Nos.: 50-361 and 50-362 Mr. James C. Holcombe Mr. Kenneth P. Baskin Vice President - Power Supply Vice President San Diego Gas & Electric Company Southern Carolina Edison Company 101 Ash Street 2244 Walnut Grove Avenue Post Office Box 1831 Post Office Box 800 San Diego, California 92112 Rosemead, California 91770 Gentlemen:

SPENT RESIN

SUBJECT:

INTERIM APPROVAL OF DEWATERING OF California Edison Company (SCF)

By a letter dated May 1, 1985, Southern Chem-Nuclear, Inc., with Nuclear requested NRC approval for replacing of wet solid radwaste treatment services and Packaging (NuPac as the vendor processes as described in the NuPac use of NuPac spent resin dewatering Station (SONGS),

Onofre Nuclear Generating Topical Report, TP-02-NP at San Unit Nos. 1, 2 and 3.

report, which describes spent resin A Nuclear Packaging, Inc., topical for NRC review in August 1984. The dewatering processes, was submitted by the NRC staff. The review of the topical topical report is being reviewed by the end of July 1985 provided that report is scheduled to be completed the remaining NRC licensing review questions NuPac submits their responses tostated in their letter to NRC dated April 30, on or before June 30, 1985, as 1985.

staff Topical Report, TP-02-NP by the NRC The preliminary review of the NuPac of the requirements set forth in Branch indicates that it meets the intent 2, "Design Guidance for Solid Radioactive Technical Position, ETSB 11-3, Rev. in Light-Water-Cooled Nuclear Power Waste Management Systems Installed 1.143, "Design Guidance for Radioactive Reactor Plant," and Regulatory Guide and Components in Light-Water-Cooled Waste Management Systems, Structures Nuclear Reactor Power Plants."

approval of their request in order to Meanwhile, SCE has requested prompt at SONGS and to proceed with dewatering alleviate wet solid radwaste storage of spent resin.

finds the topical report, the NRC staff Based on our preliminary review of approval effective until our review of the request acceptable as an interim complete. This interim approval will NuPac's licensing topical report is testing of dewatering detection provide also an opportunity for fielddeveloped by NuPac. These field test instrument which is currently being

results and description of the instrument selected are needed to complete nur review of the NuPac topical report. All such field tests on the waste containers should be supplemented with conventional pumping method of drainable liquid to ensure the dewatered container meet free standing liquid criteria set forth in Section 61.56(a)(3) of 10 CFR Part 61.

Ve hereby grant interim authorization to proceed with dewatering of spent resin in accordance with NuPac Operations and Maintenance Procedure, OM-17, Rev. 0, dated October 22, 1984, the SONGS PCP (San Onofre Health Physics Procedure S023-VII-8.5.1, Rev. 1, dated April 11, 1984) and SONGS Padwaste Solidification Procedure (S0123-VII-8.5, Rev. 2, dated April 3, 1984). The dewatered waste should be classified in accordance with SONGS Solid Radioactive Waste Packaging, Labeling, and Shipping Procedure (S0123-VIT-8.1, Rev. 4, dated April 11,-1984) which complies with Section 61.55 of 10 CFR 61.

Sincerely, George W. Knighton, Chief Licensing Branch No. 3 Division of Licensing cc: See next page

I I ~.--

San Onofre Mr. Kenneth P. Baskin Vice President Southern California Edison Company "*v.

2244 Walnut Grove Avenue P. 0. Box 800 Rosemead, California 91770 Mr. James C. Holcombe Vice President - Power Supply San Diego Gas & Electric Company 101 Ash Street Post Office Box 1831 San Diego, California 92112 Mr. Mark Medford Charles R. Kocher, Esq. Southern California Edison Company James A. Beoletto, Esq. 2244 Walnut Grove Avenue Southern California Edison Company P. 0. Box 800 2244 Walnut Grove Avenue Rosemead, California 91770 P..O. Box 800 Rosemead, California 91770 Dr. L. Bernath Manager, Nuclear Department San Diego Gas & Electric Company Orrick, Herrington & Sutcliffe P. 0. Box 1831 ATTN: David R. Pigott, Esq. San Diego, California 92112 600 Montgomery Street San Francisco, California 94111 Richard J. Wharton, Esq.

University of San Diego School of Law Alan R. Watts, Esq. Environmental Law Clinic Rourke & Woodruff San Diego, California 92110 Suite 1020 1055 North Main Street Charles E. McClung, Jr., Esq.

Santa Ana, California, 92701 Attorney at Law 24012 Calle de la Plaza/Suite 330 Mr. V. C. Hall Laguna Hills, California 92653 Combustion Engineering, Inc.

1000 Prospect Hill Road Region Administrator-Region V/NRC Windsor, Connecticut 06095 1450 Maria Lan/Suite 210 Walnut Creek, California 92672 Mr. S. McClusky Bechtel Power Corporation P. 0. Box 60860, Terminal Annex Resident Inspector, San Onofre NPS Los Angeles, California 90060 c/o U. S. NRC Post Office Box 4329 Mr. C. B. Brinkman San Clemente, California 92672 Combustion Engineering, Inc.

7910 Woodmont Avenue Bethesda, Maryland 20814 Mr. Dennis F. Kirsh U.S. Nuclear Regulatory Commission - Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596