ML13308A836
| ML13308A836 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/14/1984 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Bronski D, Mcdonald J Sierra Club |
| References | |
| NUDOCS 8405230446 | |
| Download: ML13308A836 (11) | |
Text
May 14, 1984 Ms. Donna Bronski Ms. Julie E. McDonald Sierra Club Legal Defense Fund Inc.
2044 Fillmore Street San Francisco, California 94115
Dear Ms. Bronski and Ms. McDonald:
This letter is in response to your letter of March 5, 1984. Before addressing your question however, we would like to distinguish between the integrated living schedule and the proposal for plant return to service.
The Integrated Living Schedule (ILS) is a plan for implementation of plant backfits (capital projects) starting with the next refueling outage.(Cycle 9).
This has also been referred to in correspondence from Southern California Edison Company (SCE) as the Plan for Managing Plant Retrofit.
The Return to Service Plan relates to those activities which must be com pleted before the plant returns to power from the current outage.
Our February 8, 1984, letter (Denton to Baskin) relates mainly to seismic re evaluation criteria for the Return to Service Plan, i.e. prior to plant restart. Long-term seismic reevaluation which may be necessary after plant restart will be addressed in the context of the ILS.
We believe your question was particularly directed at the status of the Return to Service Plan. By letter dated April 16, 1984, (enclosed) Southern California Edison Company summarized the status of activities related to both plans, including their schedule for responding to the issues in the NRC staff's February 8, 1984 evaluation.
Sincerely, Original signed by Richard Emch for Dennis M. Crutchfield, Chief 840624466405-14 Operating Reactors Branch #5 PDR ADOCK.05000206 Division of Licensing P._-
Enclosure:
Ltr. fr. SCE dated April 16, 1984
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Ms. Donna Bronski Ms. Julie E. McDonald Sierra Club-Legal Defense Fund Inc.
2044 Fillmore Street San Francisco, California 94115
Dear Ms. Bronski and Ms. McDonald:
This letter is in response to your letter of March 5, 1984. Before addressing your question however, we would like to distinguish between the integrated living schedule and the proposal for plant return to service.
The Integrated Living Schedule (ILS) is a plan for implementation of plant backfits (capital projects) starting with the next refueling outage (Cycle 9).
This has also been referred to in correspondence from Southern California Edison Company (SCE) as the Plan for Managing Plant Retrofit.
The Return to Service Plan relates to those activities which must be com pleted before the plant returns to power from the current outage.
Our February 8, 1984, letter (Denton to Baskin) relates mainly to seismic re evaluation criteria for the Return to Service Plan, i.e. prior to plant restart. Long-term seismic reevaluation which may be necessary after plant restart will be addressed in the context of the ILS.
We have not yet received a written response to our February 8, 1984 letter.
We believe that your question was directed at the status of the Return to Service Plan. It is our understanding, based,on informal telephone con versations with representatives of SCE, that they will accept most of the alternative criteria. Formal acceptance is still awaited. The NRC staff will, continue to work with SCE to finalize the seismic reevaluation criteria for plant restart.
For your information, by letter dated February 27, 1984 (enclosed) Southern California Edison Company submitted a revised ILS proposal in response to our January 20, 1984 letter. This proposal is under NRC staff review.
Sincerely, Dennis M. Crutchfield, Chief Operating Reactors Branch #5 Division of Licensing
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Ms. Julie E. McDonald SEPB Sierra Club Legal Defense Fund Inc.
2044 Fillmore Street San Francisco, California 94115
Dear Ms. Bronski and Ms. McDonald:
This letter is in response to your letter of March r, 1984. First of all, we would like to distinguish between the integrated living schedule and the proposal for plant return to service.
The Integrated Living Schedule (ILS) is a plan for implementation of plant backfits (capital projects) starting with the next refueling outage (Cycle 9).
This has also been referred to in correspondence from Southern California Edison as the Plan for Managing Plant Retrofit.
The Return to Service Plan relates to those activities which must be com pleted before the plant returns to power from the current outage.
Our February 8, 1984, letter (Denton to Baskin) relates mainly to seismic re evaluation criteria for the return to service plan, i.e. prior to plant restart. Long-term seismic reevaluation that is, after plant restart, will be addressed in the context of.the ILS.
By letter dated February 27, 1984 (enclosed) Southern California Edison sub mitted a revised ILS proposal in response to our January 20, 1984 letter.
This proposal is under NRC staff review.
We have not yet received a written response to our February 8, 1984 letter on the seismic reevaluation criteria for plant return to service.
It is our understanding based on telephone conversations with representatives of SCE, that they will accept most of the alternative criteria.
The NRC staff will continue to work with SCE to finalize the seismic reevaluation criteria for plant restart.
Sincerely, Dennis M. Crutchfield, Chief Operating Reactors Branch #5 Division of Licensing
Enclosure:
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May 14, 1984 Ms. Donna Bronski Ms. Julie E. McDonald Sierra Club Legal Defense Fund Inc.
2044 Fillmore Street San Francisco, California 941115
Dear Ms. Bronski and Ms. McDonald:
This letter is in response to your letter of March 5, 1984. Before addressing your question however, we would like to distinguish between the integrated living schedule and the proposal for plant return to service.
The Integrated Living Schedule (ILS) is a plan for implementation of plant backfits (capital projects) starting with the next refueling outage (Cycle 9).
This has also been referred to in correspondence from Southern California Edison Company (SCE) as the Plan for Managing Plant Retrofit.
The Return to Service Plan relates to those activities which must be com pleted before the plant returns to power from the current outage.
Our February 8, 1984, letter (Denton to Baskin) relates mainly to seismic re evaluation criteria for the Return to Service Plan, i.e. prior to plant restart. Long-term seismic reevaluation which may be necessary after plant restart will be addressed in the context of the ILS.
We believe your question was particularly directed at the status of the Return to Service Plan.
By letter dated April 16, 1984, (enclosed))Southern California.Edison Company summarized the status of activities related to both plans, including their schedule for responding to the issues in the NRC staff's February 8, 1984 evaluation.
Sincerely, Dennis M. Crutchfield, Chi f Operating Reactors Branch #5 Division of Licensing
Enclosure:
Ltr. fr. SCE dated April 16, 1984
Southern California Edison Company P. 0. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD. CALIFORNIA 91770 M.O. MEDFORD TELEPHONE MANAGER, NUCLEAR LICENSING (213) 572.1749 April 16, 1984 Director, Office of Nuclear Reactor Regulation Attention:
D. M. Crutchfield, Chief Operating Reactors Branch No. 5 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:
Subject:
Docket No. 50-206 Return-to-Service Requirements San Onofre Nuclear Generating Station Unit 1
References:
A. Letter, Robert Dietch, SCE, to H. R. Denton, NRC, dated June 10, 1983 B. Letter, Harold R. Denton, NRC, to K. Baskin, SCE, dated February 8, 1984 C. Letter, Darrell G. Elsenhut, NRC, to Kenneth P. Baskin, SCE, dated March 29, 1984 D. Letter, D. M. Crutchfield, NRC, to R. Dietch, SCE, dated August 11, 1982 E. Letter, D. M. Crutchfield, NRC, to R. Dietch, SCE, dated March 14, 1983 The Reference A letter delineated SCE's plans for continued work on San Onofre Unit 1. In that letter, it was specifically indicated that until such time as concurrence was obtained on two plans for reducing capital expenditures and improving the capacity factor of the unit, that only limited areas of work would continue. The two plans for which concurrence was requested are:
- 1. The "Plan for Early Return to Power" to determine the scope of modifications that should be implemented as part of the seismic reevaluation program prior to return-to-power, and
- 2. The "Plan for Managing Plant Retrofit" to determine the method and techniques to be used to establish a long-term integrated plant modification schedule.
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Mr. D. M. Crutchfield
-2 The Reference Band C letters provided NRC concurrence with the above two plans.
The Reference B letter provided general concurrence with the plan and criteria which, when implemented, will be sufficient to demonstrate the capability to achieve a hot standby condition for a postulated design basis earthquake. This will allow plant restart prior to complete resolution of the Systematic Evaluation Program (SEP) seismic issues.
The Reference C letter provided NRC staff concurrence that our plan for an Integrated Living Schedule appears consistent with staff guidelines for such schedules, and the dates, in general, are acceptable.
With receipt of NRC concurrence in these programs, SCE is now undertaking efforts necessary to return San Onofre Unit 1 to service. In support of this effort a list has been developed which identifies outstanding submittals, including those associated with requirements that must be resolved prior to restart, as well as those associated with ongoing licensing actions (marked with an asterisk in the enclosure) that are a major concern but which are not directly necessary for the restart effort. Enclosure 1 is a list of such actions and includes an indication of the dates by which SCE will provide these submittals in order to support a startup date now anticipated in mid-September, 1984. It is our intention to adhere to the submittal dates for the return-to-service requirements in order that the staff will in general have at least three and a half months for review and approval of those items requiring extensive NRR actions. Where extensive NRR actions are not required, the dates are scheduled prior to restart.
Our plans currently entail leaving Mode 5 operation on about August 1, 1984. This will be for the purpose of performing hot functional testing while completing the seismic upgrades necessary for restart. The hot functional testing will require operating in modes as high as Mode 3, Hot Standby. Our interpretation of the outstanding Orders (References D and E) is that hot functional testing or other operation in Modes 4 or 3 does not constitute leaving a "shutdown condition."
Operating at these modes does not pose a safety concern especially due to the low levels of decay heat resulting from the extended period of plant shutdown. We are currently in the process of reviewing any Technical Specification change requirements which may be required to be implemented prior to leaving Mode 5 to support these testing requirements. Other than these potential Technical Specification changes, SCE considers that there are no licensing constraints to entry into Modes 3 and 4. Final resolution of the Orders will remain a constraint to Mode 2 operation in mid-September. provides dates for continued submittals related to the SEP. It is our understanding that it is the NRC staff's intention to complete the Integrated Assessment of the SEP on a schedule to coincide with return-to-service. This will allow identification of any remaining areas in the SEP which may result in plant backfit. The schedule for any identified backfits would then be included in a revision to the Integrated Living Schedule.
Mr. D. M. Crutchfield
-3 In summary, SCE now believes that we have reached agreement on the two plans necessary for the return-to-service of San Onofre Unit 1. In order to support plant startup in mid-September, 1984 a list of submittals for License Amendments,.etc., has been identified and is enclosed. We are prepared to work with the staff as necessary to facilitate review of these submittals.
If there are any additional areas which the NRC staff believes should receive additional attention to support return-to-service, please let me know.
Very truly yours, Enclosures
- 1.
List of submittals necessary to support mid-September, 1984 return-to service
- 2. List of submittals to support completion of the SEP Integrated Assessment cc: 3. B. Martin, Regional Administrator U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region V A. E. Chaffee (USNRC Resident Inspector, San Onofre Units 1, 2 and 3)
A. 3. D'Angelo (USNRC Resident Inspector, San Onofre Unit 1)
NON-SEISMIC RETURN-TO-SERVICE SUBMITTAL SCHEDULE SAN ONOFRE UNIT 1 Submittal Requirement Schedule
- 1. Conceptual Design Information for Fire Protection 4/20/84 Dedicated Safe Shutdown System
- 2. Request for Deferral of Post-Accident Sampling System 5/1/84 Implementation Date
- 3. Exemption Request to the Environmental Qualification 6/30/84*
March 31, 1985 Deadline
- 4. Proposed Change to Fire Protection Technical 6/1/84 Specification for New Modifications (Superceeding Proposed Change No. 92)
- 5. Response to NRC Questions on Operating History and 6/15/84*
Reliability of Transamerica Delaval Diesel Generators
- 6. Information Concerning Post-Trip Review Program 7/1/84 and Procedure
- 7. Revised Proposed Change Which Includes Auxiliary 6/1/84*
Saltwater Cooling Pumps and Screen Wash Pumps as Backup
- 8. Response to NRC Comments on Proposed Change No. 128 4/30/84*
Regarding Redundancy in Reactor Core Heat Removal Methods During All Modes of Operation
- 9. Revised Proposed Change No. 71 on Overpressurization 5/15/84 Mitigation System
- 10.
Integrated Living Schedule License Condition Application 6/1/84*
- 11.
Proposed Change on Heatup and Cooldown Curves 5/25/84*
- 12.
Proposed Change No. 130 on Organization Change 5/1/84*
- 13.
Reanalysis of Qualification of Charging Pumps to Include 8/1/84 Increased Temperature
- 14. License Condition Application Requiring:
6/1/84
- a. Shutdown Within 6EFPM for Steam Generator Inspection
- b. Inspection Plan Report 45 Days Prior to Shutdown for Inspection
- These items are not absolute requirements for return-to-service, but will be supported to the extent possible without affecting the other commitments.
-2 Submittal Requi rement Schedule
- 15.
Proposed Change on Plant Staff Overtime 6/1/84*
- 16.
Proposed Post-TMI Technical Specifications in Response 6/1/84*
to Generic Letters 82-16 and 83-37
- 17.
Proposed Change to Technical Specifications on 5/15/84 Auxiliary Feedwater System
- 18.
Reactor Trip Breaker Maintenance Program and Breaker 7/1/84 Test Results (IE Bulletin 83-01)
- 19.
Report on Defective Ray Miller Products (IE Bulletin 83-07) 7/1/84*
- 20.
Plans and Schedules in Response to Failure of General 7/20/84 Electric HFA Relays in Safety Related Systems (IE Bulletin 84-02)
- 21.
Revision of Proposed Change No. 126, Auxiliary Electrical 6/1/84 Supply and Emergency Power System Periodic Testing SEISMIC RETURN-TO-SERVICE SUBMITTAL SCHEDULE SAN ONOFRE UNIT 1
- 1. Example Seismic Evaluations of Piping 6/15/84
- 2. Report on Seismic Evaluation of Electrical Raceways 6/15/84
- 3.
Test Report on Masonry Walls 4/12/84
- 4. Results of Seismic Reevaluation of Vent Stack 5/31/84
- 5. Additional Information Related to In-Situ Backfill 4/20/84 Soil Conditions
- 6. Example Pipe Support Bending Calculations 5/31/84*
- 7. Review of EG&G Piping Calculations 5/11/84*
- 8. Report on Seismic Reevaluation of Mechanical 6/15/84 Equipment
- 9. Results of Branch Line Decoupling Study 5/31/84*
- These items are not absolute requirements for return-to-service, but will be supported to the extent possible without affecting the other commitments.
SEP INTEGRATED ASSESSMENT Topic Description Submittal Schedule II-1.C Control Room HVAC Design Study August 1, 1984 II-3.A, Information on Design Basis Groundwater April 20, 1984 II-3.8 II-3.B.1 Evaluation of Need for Tsunami Gates April 20, 1984 III-1 Program for Evaluation of Component June 1, 1984 Classification Requirements 111-2 Analysis of Design Basis Tornado August 1, 1984 III-4.A Probabilities and Plan for Plant Protection from Such Phenomena III-3.C Details of Program to Inspect Water April 20, 1984 Control Structures III-5.A Schedule for Performance of Leak-Before-November 16, 1984 III-5.B Break on High Energy Lines IV-2 Results of Analysis to Demonstrate April 20, 1984 Potential Reactivity Control Single Failures are Bounded in Accident Analysis VI-7.B Results of Evaluation of Adequacy of April 20, 1984 RWST Redundant Level Instrumentation VI-7.C-2 Schedule for Assessing Impact on Safety April 20, 1984 of Potential ECCS Single Failures VIII-l.A Provide Result of Design Review of Degraded August 1, 1984 Grid Voltage Protection System IX-3 Evaluation of Need for Tsunami Gates April 20, 1984 IX-5 Evaluation of Existing Ventilation Systems in June 15, 1984 4 kV, 480 V and Battery and Inverter Rooms XV-1 Evaluation of Time Available for Increased April 20, 1984 Feedwater Flow Transient GEH:1424F