ML13305A573
| ML13305A573 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/23/1984 |
| From: | Knighton G Office of Nuclear Reactor Regulation |
| To: | Baskin K, Holombe J San Diego Gas & Electric Co, Southern California Edison Co |
| References | |
| NUDOCS 8405150083 | |
| Download: ML13305A573 (4) | |
Text
4.
Docket No.:
50-361 APR 2 3 1984 Mr. Kenneth P. Baskin Mr. James C. Holombe Vice President Vice President - Power Supply Southern California. Edison Company San Diego Gas & Electric Company 2244 Walnut Grove Avenue 101 Ash Street Post Office Box 800 Post Office Box 1831 Rosemead, California 91770 San Diego, California 92112 Gentlemen:
Subject:
Draft Facility Attachment, San Onofre Unit 2 We wish to thank you for your comments regarding the draft Facility Attachment (FA) prepared for the application of IAEA safeguards at San Onofre 2. The following observations relate to each specific comment in your January 17, 1984 letter.
- 1. The changes you suggest for Code 1.1, 1.3, 1.4, and 2 are acceptable.
- 2. All interpretations in your comments on Code 2.2 are acceptable.
- 3. In Code 3.1.3,-the statement "In case of prolonged shutdown of a year or longer, physical inventory takings shall be performed once every 12 months" means that all material not in the core will be inventoried at least once per year. Fuel assemblies in the core are normally subject to verification only at time of refueling. Book values will be used at other times. The reactor head need not be removed expressly to take a physical inventory of the fuel in the core.
- 4. Your interpretation of "Item counting and verification" in Codes 3.1.3 and 5.1.2 is acceptable.
- 5. Code 3.2.1 indicates that appropriate combinations of containment and surveillance methods and techniques may be used by the IAEA at the reactor and at fresh ad spent fuel storage areas, including access routes. Code 3.2.2 specifies that seals may be used only to insure the containment of the reactor vessel and on shipping casks of.spent fuel, and that cameras will be used for surveillance of fuel movement into and out of the fresh and spent fuel storage areas. Cameras may also be used in the containment area as a temporary replacement for the seals removed from the reactor during refueling. No other use is anticipated. Code 7.4.4 indicates that during inspections, the IAEA may have access to the fuel building, fuel handling and storage area and access routes to 1) observe the refueling and spent fuel removal operations, 2) apply, examine and remove IAEA seals, and 3) service and maintain their cameras. We feel that Codes 3.2 and 7.4.4 of the facility attachment are clear and need no special interperation.
84015003 840423 PDR ADOCK 05000361 F F.
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- 6. We feel that Codes 3.2.2 and 6.4.1 need no special clarification related to switching from normal to emergency lighting, assuming that the intensity of light from either source is adequate. Insufficient lighting, blocking the view of the camera or physically moving the camera would constitute inteference that requires reporting.
- 7. Since the control of startup and calibration sources is straightforward and requires minimal effort, the U. S. has decided that an exemption from the IAEA for such item is not needed. Therefore, the reference to small quantities in Codes 4.1 and 4.2 should remain.
- 8. Your interpretation of recording "Nuclear loss (uranium burnup) and nuclear production...." in Code 5.1.1 means "nuclear loss and production will be calculated and recorded at the time of taking the core physical inventory during refueling outage and at an interval no greater than six months."
- 9. Your suggested change in Code 5.3 is acceptable.
- 10. We cannot accept your suggestion to change the timing of the ICR from 30 days to 60 days. The U. S. is committed to submit ICRs to the IAEA within 30 days of the end of the month in which the transaction occurs.
Southern California Edison is required to submit the 741 forms, from which ICRs are prepared, in a much shorter time. Reference NUREG/BR-0006 "Instructions of Completing Nuclear Material Transaction Reports" for specifics.
- 11.
Your interpretation of the meaning of "Concise Notes" in Code 6.2 is acceptable.
- 12. Since sources will not be exempted (reference Item 7), we find your proposed changes in 6.3.2 unnecessary.
- 13. We cannot accept your suggestion to change the timing of the dispatch for MBRs from 30 to 60 days. The U.S. is committed to submit the MBRs and PILs to the IAEA within 30 days of each physical inventory. Page 19 of NUREG/BR-0007 "Instructions for Completing Materials Balance Report, Physical Inventory Listing and Concise Note Forms" provides specifics for timing your submittal.
- 14. Your interpretation of the meaning of "Inspections" in Code 7 is acceptable.
- 15. We agree with your statement that spent fuel shipments may be made to other than a reprocessing plant and, therefore, will propose that the facility attachment in Code 7.3(d) be changed to read:
"That if irradiated fuel shipments were made that there would be a means of correlating the identify and number of fuel assemblies at the receipt facility."
- 16.
Your interpretation of "30 man-days per year if one refueling occurs" in Code 7.3 is acceptable.
- 17.
Your interpretation of the "Verification of the inventory, i.e., by item counting and identification" in Codes 7.4.2 and 7.4.3 is acceptable.
- 18. Since it is desirable to avoid the use of specific names in Codes 7.7 and 7.8, we request that you provide us with the titles of the people identified so only that information can be used in the FA.
- 19. Your suggested change in Code 7.10 is acceptable.
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- 20. The "Termination" statement you proposed be added at the end of the Agreement, or an equivalent statement, is acceptable.
Sincerely, George W. Knighton, Chief Licensing Branch No. 3 Division of Licensing cc:
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0 San Onofre Mr. Kenneth P. Baskin Vice President Southern California Edison Company 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 Charles R. Kocher, Esq.
Mr. Mark Medford James A. Beoletto, Esq.
Southern California Edison Company Southern California Edison Company 2244 Walnut Grove Avenue 2244 Walnut Grove Avenue P. 0. Box 800 P. 0. Box 800 Rosemead, California 91770 Rosemead, California 91770 Mr. Henry Peters Orrick, Herrington & Sutcliffe San Diego Gas & Electric Company ATTN: David R. Pigott, Esq.
P. 0. Box 1831 600 Montgomery Street San Diego, California 92112 San Francisco, California 94111 Richard J. Wharton, Esq.
University of San Diego School of Alan R. Watts, Esq.
Law Rourke & Woodruff Environmental Law Clinic Suite 1020 San Diego, California 92110 1055 North Main Street San Clemente, California, 92701 Charles E. McClung, Jr., Esq.
Attorney at Law Mr. V. C. Hall 24012 Calle de la Plaza/Suite 330 Combustion Engineering, Inc.
Laguna Hills, California 92653 1000 Prospect Hill Road Windsor, Connecticut 06095 Region Administrator-Region V/NRC 1450 Maria Lan/Suite 210 Mr. S. McClusky Walnut Creek, California 92672 1450 Maria Lane/Suite 210 Walnut Creek, California 94596 Resident Inspector, San Onofre NPS c/o U. S. NRC Mr. C. B. Brinkman Post Office Box 4329 Combustion Engineering, Inc.
San Clemente, California 92672 7910 Woodmont Avenue Bethesda, Maryland 20814 Mr. Dennis F. Kirsh U.S. Nuclear Regulatory Commission CRegion V
1450 Maria Lane, Suite 210 Walnut Creek, California 94596