ML13309A273
| ML13309A273 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/08/1992 |
| From: | Rosenblum R SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9207150211 | |
| Download: ML13309A273 (29) | |
Text
A Southern California Edison Company 23 PARKER STREET IRVINE, CALIFORNIA 92718 R. M. ROSENBLUM July 8, 1992 TELEPHONE MANAGER OF (714) 454-4505 NUCLEAR REGULATORY AFFAIRS U. S. Nuclear Regulatory Commission Attention:
Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Docket No. 50-206 TAC List Status San Onofre Nuclear Generating Station (SONGS), Unit 1 Enclosed is SCE's proposed disposition of San Onofre Unit 1 open items listed on the NRC TAC list dated March 10, 1992. Also included is SCE's proposed disposition of Cycle 12 FTOL Items which do not have a TAC item number. The disposition of these items reflects SCE's plans to permanently shut down San Onofre Unit 1 at the end of the current fuel cycle.
The disposition of the items are broken down into five categories as listed below. The items are listed by NRC TAC item in Enclosures 1 through 4. The items in Enclosure 5 are listed by Cycle 12 FTOL item number because an NRC TAC item number has not yet been assigned.
- - Items Required for Cycle 11, Items Required for a Mid-Cycle Fuel Shuffle,
- - Items Required Post-Shutdown, Items Closed or Not Required Post-Shutdown, and
- - Cycle 12 FTOL Items Which are Not on TAC List. is a list of NRC TAC items requiring either NRC or SCE action to support ongoing activities for Cycle 11 operation. is a list of NRC TAC items that require action only if SCE decides to pursue a mid-cycle fuel shuffle. If a mid-cycle fuel shuffle is not pursued, then these items will be categorized as "Items Closed or Not Required Post-Shutdown." NRC review of these items is not required unless notified by SCE of plans to proceed with a mid-cycle fuel shuffle at San Onofre Unit 1.
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Document Control Desk
-2 is an NRC TAC item required after San Onofre Unit 1 shuts down, but which may undergo changes in scope in anticipation of the plant's defueled status. is a list of NRC TAC items which are closed or will not be required for San Onofre Unit 1 post-shutdown operation. Some of the items are considered closed by SCE due to information already provided to the NRC.
These items are noted as such in the enclosure. The other items are no longer required due to SCE's plans for the permanent shutdown of San Onofre Unit 1. items are Cycle 12 FTOL Items that were not assigned an NRC TAC Item number. SCE included these items to inform the NRC of our plans for these projects in view of the impending permanent shutdown of San Onofre Unit 1.
If you have any questions, please contact me.
Very truly yours, Enclosures cc:
J. B. Martin, Regional Administrator, NRC Region V George Kalman, NRC Senior Project Manager, San Onofre Unit 1 J. 0. Bradfute, NRC Project Manager, San Onofre Unit 1 C. W. Caldwell, NRC Senior Resident Inspector, San Onofre Units 1, 2&3 ITEMS REQUIRED FOR CYCLE 11 The items listed in this enclosure must be completed to support ongoing activities for Cycle 11 operation.
WIND AND TORNADO LOADINGS TAC #M63078 Action required by:
NRC This is Cycle 12 FTOL Item 2, "Tornado Modifications."
This issue originated as part of the Systematic Evaluation Program. A submittal was made on August 31, 1990.
By using probabilistic risk assessment (PRA) techniques, it was concluded that there were no cost beneficial modifications for wind and tornado loadings. This was due primarily to the low risk of a tornado.
Following an NRC plant visit on December 18 and 19, 1991, SCE agreed to provide the NRC with additional cost benefit analysis regarding the 480V room wall.
This information was submitted to the NRC on June 25, 1992.
SCE has requested NRC review and issuance of an SER.
THERMAL SHIELD SUPPORT REPAIR TAC #M75107 There have been multiple submittals related to the repair of the thermal shield supports which were completed during the Cycle 11 Refueling Outage.
The NRC approved the revised support design in an SER dated December 19, 1990.
Addressed below are the open items from the SER.
Analytical Model - As Found Evaluation Action required by:
NRC The NRC requested an analysis demonstrating that the analytical model and evaluation methods used to qualify the replacement thermal shield supports were conservative. A concern arose because design of the replacement supports was completed prior to shutdown and inspection of the old supports during the Cycle 11 refueling outage. The new design was done using refined versions of the existing analytical models.
Upon inspection, additional support damage was visible.
SCE submitted an analysis on July 15, 1991 which confirmed that the models used in the design of the new support system were conservative by applying them to finite element models of the old support system. The 1-1
analytical model predicted failures that were more severe than those actually found during the inspections.
NRC staff review of this analysis is currently in progress and should continue in support of Cycle 11 operation.
Root Cause Evaluation of Failed Fasteners Action required by:
NRC The NRC requested that a root cause evaluation be performed for the fasteners in the old thermal shield support system. SCE completed this evaluation and submitted it to the NRC on April 9, 1991.
The evaluation confirmed that the failures were caused by low cycle, high stress fatigue conditions caused by vibration due to failure of the upper flexures. This type of failure will be prevented by the design of the new support system.
The root cause report is currently under review by the NRC staff. This
,review should continue in support of Cycle 11 operation.
Technical Specifications for Inspection and Monitoring No action required.
The NRC requested that technical specifications be developed for monitoring the condition of the thermal shield during operation and for inspecting the support system when the plant is shut down.
Currently, there is a license condition which requires the condition of the thermal shield to be monitored during power operation. The license condition does not address inspection of the support system during plant shutdown.
The existing license condition requires essentially the same monitoring program that would be required by a technical specification. Because of this, and since there are currently no plans to perform a thermal shield support inspection or operate the reactor past Cycle 11, there is no need for Technical Specifications for the inspection of the support system and a monitoring program. Therefore, SCE does not plan to submit new technical specifications.
Corrosion Testing No action required.
The NRC performed corrosion testing on the bolts used in the replacement thermal shield supports. This has been completed and is documented in a letter from the NRC dated January 27, 1992.
No further action is necessary.
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Thermal Shield Monitoring Action required by:
SCE/NRC The NRC requested SCE to submit an evaluation showing the expected amplitudes and frequencies of postulated failures, that would be detected on the neutron and acoustical noise monitoring systems.
SCE was also required to submit an evaluation documenting the acceptance criteria to be used in the thermal shield monitoring program. This information was provided to the NRC by letter dated September 20, 1991.
During a telephone call the week of March 16, 1992, the NRC requested us to lower the acceptance criteria by 25%. During discussions with the NRC an incorrect monitoring curve was identified. Therefore, SCE will submit a revised curve to the NRC. The 25% issue has been resolved for Cycle 11 operation. SCE submittal of the revised curve and NRC issuance of the safety evaluation is the only activity that remains.
Acoustical Noise Monitoring Action required by:
NRC During the San Onofre Unit 1 Cycle 11 refueling outage SCE made improvements to the Acoustical Noise Monitoring System. These improvements were documented in a letter to the NRC dated August 16, 1991.
The NRC is currently reviewing these improvements.
This review should continue in support of Cycle 11.
As-Built Evaluation Action required by:
NRC During an October 3, 1990 meeting with the NRC staff, the NRC requested an evaluation of the support system taking into account modifications to the design which were necessary during the assembly process. The NRC required this analysis to confirm that the as-built configuration did not significantly alter the analytical model which the NRC had reviewed in approving the replacement support design.
Our revised analysis was submitted to the NRC on September 20, 1991.
The revised analysis confirms that the design changes made during the installation process do not significantly affect the conservatism of the new support design. This report is currently under NRC staff review.
This review should continue in support of Cycle 11.
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SEISMIC QUALIFICATION OF EQUIPMENT IN OPERATING PLANTS - GENERIC LETTER 87-02, UNRESOLVED SAFETY ISSUE A-46 TAC #M76356 Action required by:
SCE This is Cycle 12 FTOL Item 8, "Seismic Adequacy of Equipment (USI A-46)."
The NRC issued Supplement 1 to GL 87-02 on May 22, 1992.
The generic letter requested a response from all USI A-46 plant licensees who are members of SQUG within 120 days. SCE will evaluate this supplement with respect to the shutdown of San Onofre Unit 1 and respond accordingly.
1-4 ITEMS REQUIRED FOR A MID-CYCLE FUEL SHUFFLE If a mid-cycle fuel shuffle is not pursued, then these items will be categorized as "Items Closed or Not Required Post-Shutdown."
SCE may perform a mid-cycle fuel shuffle which entails exchanging fuel from the reactor with partially expended fuel in the spent fuel pool.
This process would extend the operation of San Onofre Unit 1 by approximately 6 months until permanent shutdown. NRC review of these items is not required unless notified by SCE of plans to proceed with a mid-cycle fuel shuffle at San Onofre Unit 1.
LOW TEMPERATURE OVERPRESSURE PROTECTION - GENERIC LETTER 90-06, GENERIC ISSUE - 70 TAC# M77376, TAC #M77449, & TAC #M79689 Technical specification changes recommended in Generic Letter 90-06 were submitted to the NRC by Amendment Application No. 194 dated May 13, 1991.
Additional responses to GL 90-06 were provided in letters dated December 27, 1990 and February 27, 1992 (inadvertently dated 1991).
Administrative controls have been implemented until NRC approval of the amendment. NRC review of this item should not continue unless SCE elects to perform a mid-cycle fuel shuffle at San Onofre Unit 1.
UNDER-ESTIMATION OF REFILL VOLUME IN LOCA ANALYSIS AND REFILL VOLUME DIFFERENCES TAC #M80050 & TAC #M80427 This item originates from the SCE discovery that the reactor vessel refill volume used in the large break loss of coolant accident (LBLOCA) analysis for San Onofre Unit 1 was underestimated by Westinghouse. In a March 29, 1991 letter to the NRC, SCE:
- 1) quantified the effect of the refill volume underestimation on the LBLOCA analysis, 2) described administrative controls instituted to assure continued safe plant operation, and 3) committed to include the provisions of those administrative controls in the San Onofre Unit 1 Technical Specifications via a future license amendment application.
SCE submitted the preliminary results of the volume difference evaluation and the final results by letters dated May 10, 1991 and May 17, 1991 respectively.
In the May 17 letter SCE committed to reperforming the San Onofre Unit 1 UFSAR Chapter 15 design basis accident analyses prior to Cycle 12 operation.
In the NRC letter dated April 12, 1991 the NRC stated that after the peaking factor currently in the Technical Specification is revised to reflect the corrected, post-accident cooling calculation, this issue would formally be 2-1
concluded. SCE submitted the amendment request to revise the peaking factor on June 18, 1991.
This amendment is still under NRC review.
NRC review of this item should not continue unless SCE elects to perform a mid-cycle fuel shuffle at San Onofre Unit 1. Since San Onofre Unit 1 will be shutdown permanently following Cycle 11, the Chapter 15 Accident Analysis will not be performed.
INTEGRATED LEAK RATE TEST - APPENDIX J EXEMPTION TAC #M80465 & TAC #M80467 Amendment Application No. 192 was submitted to the NRC on May 22, 1991 and is currently under NRC staff review. As a result of recalculating the containment peak pressure and temperature following a LOCA, the pressure slightly increased. A containment leak rate test'pressure accounting for the increased peak pressure was used in the leak rate tests following the Cycle 10 refueling outage. This amendment includes in the technical specifications the increased test pressure for the containment leak rate testing and decouples the integrated leak rate test from the 10-year inservice inspection. NRC review of this item should not continue unless SCE elects to perform a mid cycle fuel shuffle at San Onofre Unit 1.
CONTROL ROD INSERTION LIMITS RESULTING FROM VOLUME ERROR AND CORE AXIAL OFFSET LIMITS TAC #M80645 & TAC #M81805 Amendment Application 196 was submitted on June 18, 1991 and would impose more restrictive limits on core axial offset than those specified in the current technical specifications. Administrative controls are currently in place and would have been replaced with the revised technical specifications once approved. The existing administrative controls are acceptable for continued Cycle 11 operation. NRC review of this item should not continue unless SCE elects to perform a mid-cycle fuel shuffle at San Onofre Unit 1.
CONTAINMENT TRI-SODIUM PHOSPHATE AND BORON INVENTORY LIMITS AMENDMENT APPLICATION 198 TAC #M81716 This amendment application was submitted on September 17, 1988. The change reflects an increase in the amount of TSP stored in the containment racks and adds new limits for the total boron inventory in the Reactor Coolant System.
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Administrative controls have been-implemented to ensure that the new limits are met until the amendment is approved. NRC review of this item should not continue unless SCE elects to perform a mid-cycle fuel shuffle at San Onofre Unit 1.
2-3 ITEMS REQUIRED POST-SHUTDOWN The item listed in this enclosure may be required after San Onofre Unit 1 shuts down, but which may undergo changes in scope in anticipation of the plant's defueled status.
SFP COOLING REQUIREMENTS REVISION TAC #M76808 This item originates from an SCE request for a revision to the spent fuel pool cooling system decay heat removal requirements of Section 9.1.3 of the San Onofre Unit 1 UFSAR. SCE submitted a request to change the UFSAR on May 16, 1990 and transmitted a supplement by letter dated June 4, 1990. The NRC issued an SER approving the change on July 16, 1990. SCE will continue to pursue modifications associated with the SFP for post-shutdown operation.
3-1 ITEMS CLOSED OR NOT REQUIRED POST-SHUTDOWN The items listed in this enclosure are closed or will no longer be required for San Onofre Unit 1 post-shutdown operation. Some of the items are considered closed by SCE due to information already provided to the NRC.
These items are noted as such in the enclosure. The other items are no longer required due to SCE's plans for the permanent shutdown of San Onofre Unit 1.
POTENTIAL EQUIPMENT FAILURES ASSOCIATED WITH GRID VOLTAGE TAC #M10051 This is Cycle 12 FTOL item 5b, "Degraded Grid Voltage."
SCE originally submitted an analysis of the 480V electric system in the 1980's.
SCE submitted a reanalysis of the Unit 1 station electric distribution system voltages on June 10, 1991.
The reanalysis took into account the significant modifications that were completed on the 480V electric system during the thermal shield repair and Cycle 11 refueling outage. This reanalysis superseded the analysis submitted during the 1980's.
Resolution of this issue was scheduled for completion prior to Cycle 12.
Since SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11, no further action on this item is required by SCE or the NRC.
REVIEW OF ASYMMETRIC LOCA LOADS SUBMITTAL TAC #M10148 This issue originates from the SCE request for an exemption from GDC 4 contained in Appendix A to 10CFR50. Specifically SCE requested that San Onofre Unit 1 be exempted from postulating pipe breaks in the primary loops for purposes of defining structural loads on or within the reactor vessel and the reactor coolant system primary loops. The SCE request was based on Generic Letter 84-04, "Safety Evaluation of Westinghouse Topical Reports Dealing with Elimination of Postulated Pipe Breaks in PWR Primary Main Loops" dated February 1, 1984. Generic Letter 84-04 approved the elimination of postulated pipe breaks as described above subject to two conditions relevant to San Onofre Unit 1:
(1) that SCE request an exemption from GDC 4, and (2) that leakage detection systems inside containment be adequate to detect a leak of one gpm within four hours and meet most other guidance contained in Regulatory Guide 1.45, "Reactor Coolant Pressure boundary Leakage Detection Systems."
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SCE requested the exemption in a letter dated September 20, 1985. SCE based their exemption on two Westinghouse topical reports, and other letters and documents referenced in the exemption letter. Condition (2) was resolved by issuance of NRC Amendment No. 119 on February 6, 1989.
Also the NRC modified GDC 4 on April 11, 1986 (54 FR 12502) by adding the following phrase:
"However, the dynamic effects associated with postulated pipe ruptures of primary coolant loop piping in pressurized water reactors may be excluded from the design basis when analyses demonstrate the probability of rupturing such piping is extremely low under design basis conditions."
In a July 25, 1989 letter, the NRC concluded that with the issuance of 54 FR 12502 an exemption to GDC-4 is not necessary provided that the conditions of GL 84-04 are otherwise satisfied. The NRC further concluded that San Onofre Unit 1 satisfied the conditions of GL 84-04, and NRC action on this matter was complete. Therefore SCE considers this item closed and no further action is required on this item by SCE or the NRC.
REL-PS-TACS -- FIRE PROTECTION SER SUPPLEMENT TAC #M11114 This item stems from the July 19, 1979 Fire Protection Safety Evaluation Report (FPSER) for San Onofre Unit 1. On February 4 1981 the NRC issued an SER supplement which responded to SCE submittals dated January 23 and September 26, 1980. The two SCE letters provided details of fire protection modifications and responded to NRC consultant comments and recommendations.
The SER supplement provided indication that most of the open items were closed. Those that were not closed had an implementation schedule consistent with San Onofre Unit 1 complying with Appendix R and 10CFR50.48.
SCE considers this item closed based on San Onofre Unit 1 being in compliance with Appendix R and 10CFR50.48.
REACTOR VESSEL CAVITY SEAL RING MISSILE POTENTIAL TAC #M13178 In a May 4, 1978 letter SCE indicated that the potential for the reactor cavity annulus seal ring or biological shielding to become a missile in the event of a LOCA inside the reactor vessel cavity would be investigated. On April 29, 1982 and September 17, 1982 SCE made two submittals on internally generated missiles, which included those generated by the reactor coolant system. On October 12 1982 the NRC issued an SER addressing SCE's submittals.
The NRC went on to conclude that the likelihood of missile generation and resultant damage to the reactor coolant system is acceptably low.
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SCE considers this item closed based on the above and therefore no further action on this item is required by SCE or the NRC.
CONTAINMENT VENTING AND AIRLOCK LEAK TESTING TAC #M42615 & TAC #M73621 This item is Cycle 11 FTOL item 18, "Containment Venting." This item was originally scheduled to be completed during the Cycle 11 refueling outage by the January 2, 1990 Order. It was rescheduled to be completed during Cycle 11 operation by NRC Amendment No. 141.
Amendment Application 170, Supplement 2 was submitted on November 11, 1991.
Amendment Application 170 stems from Multi-Plant Action Item B-24 and was originally submitted on June 6, 1989. It incorporates a limiting angle on the containment vent valves, adds leak testing criteria for the vent valves and airlocks, proposes to lower the airlock test pressure from 10 psig to 8 psig, and limits the amount of time that the vent valves may be open during power operation. Additional information on the leak testing criteria was requested by the NRC reviewer.
Administrative controls are currently in place to limit the amount of time the containment vent valves are open and mechanical stops limit the opening angle.
The airlocks continue to be tested at 10 psig in compliance with the existing technical specifications. Since SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11 and since the reactor will be defueled, maintaining containment integrity will no longer be necessary. Therefore, no further action on this item is required by SCE or the NRC.
ESF RESET CONTROL DESIGN DEFICIENCY - IE BULLETIN 80-06 TAC #M42777 This is Cycle 12 FTOL item 18, "LCV 1100 B,C,D."
This item originated from review of the Safety Injection System reset function. SCE completed most of the modifications in the early 1980's as documented in the NRC SER issued on March 30, 1983.
SCE however committed to completing the.modification on valves MOV-LCV-1100 B, C, and D by Cycle 12.
The modification was subsequently completed during the Cycle 11 refueling outage.
SCE considers this item closed based on the above and therefore no further action on this item is required by SCE or the NRC.
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SEISMIC QUALIFICATION OF THE AUXILIARY FEEDWATER SYSTEM TAC #M43664 This item is a result of Generic Letter 81-14 regarding the seismic qualification of the auxiliary feedwater system. SCE provided a response on December 9, 1981 and responded to additional NRC questions from December 14, 1981 by letter dated March 15, 1982.
The December 9 letter stated the discharge side of the AFW pumps were seismically designed and the suction side required additional modifications.
These modifications would be performed consistent with the Seismic Reevaluation Program. The March 15 letter addressed seismic qualification of electrical components. Although it was felt that these components were seismically qualified, SCE committed to additional evaluations of these components during the Seismic Reevaluation Program. The seismic qualification of the AFW was completed during the Seismic Reevaluation Program as documented in NRC SER dated July 11, 1986.
SCE considers this item closed based on the above and therefore no further action on this item is required by SCE or the NRC.
INADEQUATE CORE COOLING MONITORING SYSTEM AND RVLIS EXTENSION REQUEST TAC #M45171 & TAC #M74629 This is Cycle 12 FTOL Item 19, "RVLIS/Core Exit Thermocouples."
This issue originates from TMI Item II.F.2.4. The NRC Order dated January 2, 1990 rescheduled the installation of the reactor vessel level indicating system from the Cycle 11 to the Cycle 12 refueling outage. An implementation plan including the upgrade of the core exit thermocouples was submitted by SCE on November 29, 1990. The NRC asked several questions, all but one of which was answered in a letter dated December 12, 1991.
The remaining issue concerns the heated junction thermocouples.
SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11.
The core will be defueled and the Reactor Coolant System drained. Because of this, inadequate core cooling monitoring systems will not be needed.
Therefore, no further action is required by SCE or the NRC.
ADEQUACY OF STATION ELECTRIC DISTRIBUTION VOLTAGE TAC #M48388, & TAC #M64952 This is Cycle 12 FTOL item Sa, "Adequacy of Station Voltage."
The NRC issued an SER and a revised Technical Evaluation Report (TER) prepared by Lawrence Livermore Laboratory (LLL) on July 29, 1983 addressing adequacy of station electric distribution voltages. The NRC concluded in the SER that the 4-4
adequacy of the station electric distribution voltage for San Onofre Unit 1 is acceptable. The safety evaluation also noted the SCE commitments to optimize certain transformer tap settings in order to maintain proper operating voltages and to initiate a voltage monitoring program to verify the results of this optimization. In 1985 these two commitments were completed.
On June 10, 1991 SCE submitted a reanalysis of the station electric distribution voltages to the NRC as a result of a major redesign of the 480VAC distribution system. NRC review of this reanalysis was scheduled to be completed for Cycle 12.
Since this is not needed for continued operation in Cycle 11 and since SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11, NRC review may be discontinued.
POWER ON PUMP SEALS TAC #M48433 This item is a TMI Action Plan item. SCE responded to the Action Plan item on January 11, 1982. The item required SCE to demonstrate the integrity of the reactor coolant pump (RCP) seals would be maintained during a loss of offsite power event.
In a July 7, 1982 letter the NRC concluded that SCE had adequately demonstrated that the RCP seals integrity would be maintained during a loss of offsite power event. The NRC letter stated that this item was resolved for San Onofre Unit 1.
SCE considers this item closed based on the above and therefore, no further action on this item is required by SCE or the NRC.
INSTRUMENTATION TO FOLLOW THE COURSE OF AN ACCIDENT (RG 1.97)
TAC #M51130 This is Cycle 12 FTOL item 11, "Reg. Guide 1.97 (Non Single Failure)."
This item stems from post-accident monitoring instrumentation requirements as addressed in R.G. 1.97.
SCE addressed this issue in submittals dated December 16, 1985; May 29, 1987; December 29, 1988; February 17, 1989; June 3, 1989; January 9, 1990; and May 2, 1990. The NRC issued an SER on February 22, 1991 which concluded that the San Onofre Unit 1 design is acceptable with respect to conformance to R.G.,1.97, Revision 2, except for several instrumentation systems that do not conform, and adequate justification for these deviations was not provided.
SCE provided additional information on July 1, 1991 and October 4, 1991. On December 31, 1991 a letter was sent to the NRC to provide a status of SCE efforts to comply with R.G. 1.97 and to reschedule the submittal date to July 1, 1992.
This directly resulted from the effort to update the list of R.G. 1.97 instruments.
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The post-accident monitoring instrumentation will not be needed after San Onofre Unit 1 permanently shuts down, therefore, no further action on this item is required by SCE or the NRC.
1.D.2.1 SAFETY PARAMETER DISPLAY SYSTEM TAC #M51280 & TAC #M74628 This is Cycle 12 FTOL item 9, "Safety Parameter Display System."
The requirement for a Safety Parameter Display System (SPDS) is TMI Action Plan item 1.D.2.1.
San Onofre Unit 1 was planning to implement SPDS during the Cycle 12 refueling.
Due to the impending permanent shutdown of San Onofre Unit 1, information obtainable (i.e. Reactor, RCS, and other parameters) from the SPDS will be unnecessary because those systems will no longer be required when San Onofre Unit 1 is in a defueled condition. Therefore, no further action is required by SCE or the NRC.
POST TRIP REVIEW DATA AND INFORMATION CAPABILITY TAC #M53630 This item is a result of Generic Letter 83-28, "Post-Trip Review:
Data and information Capability."
The NRC found two discrepancies with the SCE initial response to the Generic Letter but stated that implementation of the SPDS during the Cycle 12 outage would resolve this issue.
Since SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11 and since the SPDS will not be implemented, resolution of this item is not necessary. Therefore, no further action is required by SCE or the NRC.
PREVENTATIVE MAINTENANCE PROGRAM FOR REACTOR TRIP BREAKERS TAC #M53935 This issue originates from Generic Letter 83-28, Section 4.2.3 and 4.2.4, and concerns the life of the reactor trip breakers. SCE provided a submittal on April 27, 1984 which predicted a lifetime of 50 years for the breakers at San Onofre Unit 1. Since this represents plant life to the year 2022, which is well beyond the plant license period, a replacement date was not incorporated into the breaker maintenance program. This issue is currently under NRC review.
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SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11.
Since the core will be defueled, NRC approval of this item is no longer required.
AUTOMATIC ACTUATION OF SHUNT TRIP FOR WESTINGHOUSE AND B&W PLANTS TAC #M55376 This item is a result of Generic Letter 83-28 Items 4.2.1 and 4.2.2 concerning the Reactor Trip Breakers. SCE originally responded to these items on November 28, 1983. Additional correspondence was sent between SCE and the NRC in subsequent years. On September 16, 1988, the NRC sent an SER to SCE finding SCEs responses to Generic Letter 83-28 Items 4.2.1 and 4.2.2 acceptable.
SCE considers this item closed based on the above and therefore, no further action on this item is required by SCE or the NRC.
DETAILED CONTROL ROOM DESIGN REVIEW
SUMMARY
REPORT TAC #M56162 This is Cycle 12 FTOL Item 14, "Control Room Design Review."
SCE submitted the final design modifications in letters dated September 16, 1990 and December 3, 1990.
SCE had planned on implementing the modifications during the Cycle 12 outage.
Since SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11, no further action on this item is required by SCE or the NRC.
CONTROL ROOM HABITABILITY AND HVAC TECHNICAL SPECIFICATIONS TAC #M56408 & TAC #M61092 This is Cycle 12 FTOL Item 16, "Control Room habitability."
This item is a post-TMI Item (III.D.3.4) concerning Control Room Habitability. The NRC identified open items during a site visit on September 26 and 27, 1989. Based on this, SCE submitted responses to these open items on April 10, 1991 and requested NRC approval of the proposed upgrades. Associated Technical Specifications have been under development by SCE for submittal to the NRC later this year. This is in accordance with the scheduling letter submitted on December 5, 1991.
The final resolution of these items were scheduled to be implemented during the Cycle 12 outage.
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SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11.
Once the reactor is defueled an upgraded.Control Room Emergency Air Treatment System will not be required to respond to a design basis LOCA. Therefore, no further action on this item is required by SCE or the NRC.
UTILITY RESPONSES TO STAFF RECOMMENDATIONS CONCERNING STEAM GENERATORS TAC #M58086 This item results from Generic Letter 85-02 in which the Staff recommended actions to be performed stemming from the NRC integrated program for the Resolution of Unresolved Safety Issues Regarding Steam Generator Tube Integrity. SCE responded on June 26, 1985 by submitting a copy of the "Steam Generator Tube Integrity Programs, San Onofre Nuclear Generating Station, Units 1, 2, and 3" to the NRC.
Since SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11, the steam generators will no longer be needed once the reactor is defueled. Therefore, no further action on this item is required by SCE or the NRC.
CONTAINMENT BUCKLING TAC #M65867 This is Cycle 11 FTOL Item 4, "SEP III - 7.B (Buckling)."
SCE submitted a revised buckling analysis for the containment structure demonstrating that the containment will resist buckling due to thermal loading during an accident.
This analysis was provided on September 26, 1991. The NRC provided SCE with a SER on June 4, 1992.
The NRC SER identified additional analyses that would be required to judge the overall acceptability of the San Onofre Unit 1 containment structure. The NRC went on to state that since permanent shutdown of Unit 1 is contemplated at the conclusion of the current fuel cycle, a requirement for the additional analysis is suspended at this time. The NRC requested, however, a response to their letter with a commitment and schedule to perform the indicated analysis in the event that the shutdown of San Onofre Unit 1 does not occur.
Since SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11 operation, this item is considered closed. Therefore, no further action on this item is required by SCE or the NRC.
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RADIOLOGICAL EFFLUENTS TECHNICAL SPECIFICATIONS TAC #M67932 & TAC #M75527 Amendment Application 175 was submitted to implement technical specifications in accordance with Generic Letter 89-01.
The NRC review of Amendment Application 175 generated questions documented in a letter from the NRC dated August 17, 1990. SCE provided a response to the NRC's concerns in a September 23, 1991 letter. The NRC issued Amendment 145 to San Onofre Unit 1 Technical.Specifications approving Amendment Application 175 on May 15, 1992.
This amendment was incorporated into the San Onofre Unit 1 Technical Specifications on June 29, 1992.
SCE considers this item closed based on the above and therefore, no further action on this item is required by SCE or the NRC.
STATION BLACKOUT TAC #M68598 This is Cycle 12 FTOL Item 7, "Station Blackout."
The original response to the 10CFR50.63 rule on station blackout was submitted on April 17, 1989.
The program was updated by a May 1, 1990 submittal.
Several submittals addressing specific open issues such as HVAC analyses and battery capacities were subsequently submitted. The NRC issued a Safety Evaluation Report (SER) of our proposed station blackout program on July 10, 1991.
SCE responded to the open items in the SER in a September 27, 1991 letter to the NRC. This is currently under NRC review.
This item is scheduled to be implemented during the Cycle 12 refueling outage.
Since San Onofre Unit 1 will be permanently shut down after Cycle 11, review of this item by the NRC may be discontinued.
LOSS OF DECAY HEAT (GENERIC LETTER 88-17)
TAC #M69773 This item originates from Generic Letter 88-17 which addressed the risk and consequences of losing decay heat removal capability during nonpower operation of pressurized water reactors. The generic letter recommended several enhancements.
SCE committed to implement these enhancements in our letters dated February 1, 1989 and March 27, 1990. In an NRC letter dated June 5, 1990, written notification from SCE was requested when the actions were completed. In a letter dated April 26, 1991, SCE provided a response that all of the commitments made as a result of Generic Letter 88-17 were fulfilled.
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SCE considers this item closed based on the above and therefore, no further action on this item is required by SCE or the NRC.
INSTRUMENT AIR (GENERIC LETTER 88-14)
TAC #M71713 This item originates from Generic Letter 88-14 which addresses the instrument air supply system affecting safety-related equipment.
SCE responded to this Generic Letter in letters from March 1989 to December 1991.
In a December 19, 1991 letter to the NRC, SCE committed to performing an Instrument Air Systems (IAS) inspection during the Cycle 12 refueling outage, which would complete SCE's response to Generic Letter 88-14.
SC'E is planning to permanently shutdown San Onofre Unit 1 after Cycle 11, therefore, no further action is required by SCE or the NRC.
REACTOR PROTECTION SYSTEM INSTRUMENTATION TAC #M71806 This is Cycle 11 FTOL Item 16, "RPS Testing."
SCE's original submittal on this issue was dated December 29, 1988 and consisted of Amendment Application 161 which requested adding a Limiting Condition for Operation and Surveillance Requirements to the San Onofre Unit 1 Reactor Protection System (RPS) Instrumentation Technical Specifications. It also requested increasing surveillance intervals for RPS components, and adding a requirement to periodically test the reactor trip breaker undervoltage and shunt trip attachments.
The NRC review of this amendment request resulted in an NRC letter dated October 31, 1989 asking for additional justification for extending the RPS surveillance intervals.
SCE responded on June 15, 1990 by removing the surveillance interval extension request but retained the other requests.
Since SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11 and since the core will be defueled, the RPS will no longer be required to protect against accidents which could cause fuel damage.
Therefore, NRC review of this item may be discontinued.
CONTAINMENT SPRAY TAC #M71807 This is Cycle 12 FTOL Item 4, "Containment Spray Testing."
Supplement 2 to Amendment Application 162 was submitted on May 22, 1991 and provides new 4-10
Technical Specifications for containment spray instrumentation. This Amendment Application is currently under NRC review and is scheduled for completion prior to Cycle 12 operation.
SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11.
Once the reactor is shutdown, design basis accidents resulting in high pressure inside containment will not be possible. As a result the Containment Spray System will no longer be required, and consequently NRC approval of this item is no longer be necessary.
PRESSURIZER SURGE LINE THERMAL STRATIFICATION (BULLETIN 88-11)
TAC #M72163 This item stems from NRC Bulletin 88-11 which addresses thermal stratification in the pressurizer surge line.
SCE responded to the NRC in letters from March 1989 to December 1991.
The December 12, 1991 SCE letter to the NRC completed the response to the bulletin by transmitting a summary of the Surge Line Stratification Analysis for San Onofre Unit 1. SCE also made a commitment to make modifications to the surge line support by the end of the Cycle 13 refueling outage.
Since SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11, the pressurizer will no longer be required. Therefore, no further action on this item is required by SCE or the NRC.
FAILURE OF WESTINGHOUSE TUBE MECHANICAL PLUGS (BULLETIN 89-01)
TAC #M73198 & TAC #M81655 This item stems from NRC Bulletin 89-01 which addressed the failure of Westinghouse Steam Generator Tube Mechanical Plugs. In a June 15, 1989 letter SCE responded to the NRC Bulletin. In June 1991 the NRC issued Supplement 2 to the Bulletin. The NRC requested SCE to submit a response verifying the information contained in WCAP-12244 for San Onofre Unit 1. SCE forwarded the response to the supplement on August 30, 1991.
In a September 28, 1991 letter the NRC found the SCE response acceptable.
SCE considers this item closed based on the above, therefore, no further action on this item is required by SCE or the NRC.
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SPDS - RESPONSE TO GL 89-06 TAC #M73703 This item originates from GL 89-06. The requirement for a Safety Parameter Display System (SPDS) is a TMI Action Plan item. San Onofre Unit 1 was planning on implementing SPDS during the Cycle 12 outage.
Due to the impending permanent shutdown of San Onofre Unit 1, information obtainable (i.e. Reactor, RCS, and other parameters) from the SPDS will be unnecessary because those systems will no longer be required when San Onofre Unit 1 is in a defueled condition. Therefore, no further action is required by SCE or the NRC.
QUALITY GROUP TAC #M73736 This is Cycle 11 FTOL Item 2, "Classification of Structures."
This issue originated from Systematic Evaluation Program Topic III-1, "Quality Group Classification of Components and Systems." A final report on this issue was submitted to the NRC on May 31, 1989 and is currently under NRC review. Since SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11, NRC review of this item may be discontinued.
INDIVIDUAL PLANT EVALUATION (IPE)
TAC #M74463 In a letter dated December 23, 1991, SCE scheduled the IPE External Events (IPEEE) to be performed after the IPE is completed. Since SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11 and since the IPE or the IPEEE are not required for continued Cycle 11 operation, no further action on this item is required by SCE or the NRC.
SAFETY IMPLICATIONS OF CONTROL SYSTEMS - STEAM GENERATOR OVERFILL TAC #74993 This is Cycle 12 FTOL Item 12, "Steam Generator Overfill" (Unresolved Safety Issue A-47). The most recent letter on this subject is dated November 27, 1991 and scheduled submittal of the evaluation of the steam generator overfill protection system coincident with the IPE submittal.
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Since SCE is planning to permanently shut down after Cycle 11 and since the Reactor Coolant System will be drained, the steam generators will no longer be needed. Therefore, no further action on this item is required by SCE or the NRC.
RVLIS EXTENSION REQUEST TAC #M75295 This issue originates from TMI Item II.F.2.4. SCE was originally scheduled to install a Reactor Vessel Level Indicating System during the Cycle 11 outage.
In an NRC Order dated January 2, 1990 the installation was rescheduled from the Cycle 11 to the Cycle 12 refueling outage. SCE considers this item closed, therefore no further action is required by SCE or the NRC.
OPERATOR TRAINING TAC #M76374 This item resulted in Amendment Application 176 and Supplement 2 which was submitted to the NRC on August 7, 1991.
This amendment application corrects editorial discrepancies and typographical errors in the technical specifications. It is currently under NRC review. The corrections can be considered an enhancement and have a minimum impact on plant operation for the remainder of Cycle 11.
SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11 and new technical specifications for the defueled condition will be submitted to the NRC. Based on the above, NRC review of this item may be discontinued.
PLANT REFERENCE SIMULATOR SCHEDULAR EXEMPTION REQUEST TAC #M76418 This item addresses the San Onofre Unit 1 Simulator Facility Certification required by 10CFR55.45 (b)(2)(iii).
In a letter to the NRC dated November 2, 1990 SCE requested an exemption from certain requirements of 10 CFR 55.45 for San Onofre Unit 1. The NRC issued an exemption for San Onofre Unit 1 on March 22, 1991.
SCE considers its actions for this item complete based on the above, therefore no further action is required by SCE or the NRC.
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TAC #M76486 This is Cycle 12 FTOL Item 3, "HELBA."
This issue is currently under NRC staff review. SCE submitted an analysis on October 31, 1991.
NRC staff review is scheduled for completion by mid-1992 and the required modifications are scheduled for the Cycle 13 refueling outage. In our October 31, 1991 letter we stated that an evaluation for the potential of component overpressurization for the turbine and fuel building would be completed and provided to the NRC.
SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11 therefore, no further action is required by SCE or the NRC.
EMERGENCY CORE COOLING SYSTEM - AMENDMENT APPLICATION 188, PCN-151 TAC #M77572 SCE submitted a supplement to Amendment Application 188 on June 5, 1992 which issued the Safety Injection System Technical Specifications. The NRC issued Amendment No. 146 on June 24, 1992 which approved the amendment application.
SCE considers this item closed based on the above and therefore no further action on this item is required by SCE or the NRC.
ECCS ACTUATION LOGIC AND VITAL BUS TRANSFER TAC #M77705 This item originates from a San Onofre Unit 1 modification of the Safeguards Load Sequencing System actuation logic. The modification allows each sequencer to start and load its associated Emergency Diesel Generator upon a safety injection signal (SIS) concurrent with the loss of its respective 4160V bus.
SCE requested an amendment to the San Onofre Unit 1 Technical Specifications and provided additional information in four letters dated from September 28, 1990 to January 31, 1991.
The NRC approved the Technical Specification with an SER transmitted on February 28, 1991.
SCE considers this item closed based on the above and therefore no further action on this item is required by SCE or the NRC.
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REACTOR COOLANT LEAKAGE - AMENDMENT APPLICATION 184 TAC #M77834 Amendment Application No. 184 was submitted to the NRC on October 16, 1990 and is presently under staff review. This change clarifies RCS leakage in the Basis of Technical Specification 3.1.4, "Leakage and Leakage Detection Systems."
Since SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11 and since the RCS will be drained, Reactor Coolant Leakage will no longer be a concern. Therefore, based on the above, NRC review on this item may be discontinued.
COMPUTER CODE REPORT FOR CORE RELOADS TAC #M77846 This issue was originated for San Onofre Units 1, 2, & 3. Since Unit 1 will be permanently shut down after Cycle 11, it can be deleted from this TAC list item. This item should continue to be tracked on the TAC list for San Onofre Units 2 and 3.
SINGLE FAILURE ANALYSIS TAC #M79020 & Cycle 12 FTOL Item #10.
This is Cycle 12 FTOL Item 10, "Single Failure Analysis (Separation &
RG 1.97)." A single failure report discussing nine issues requiring modifications as a result of the 1990 single failure analysis of the Emergency Core Cooling System was submitted on February 27, 1991.
This report and the single failure analysis are currently under NRC staff review.
Since SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11, the Emergency Core Cooling System will not be required. Therefore, NRC review of this item may be discontinued.
CORE REACTIVITY MONITORING REQUIREMENTS - AMENDMENT APPLICATION 197 TAC #M81804 This amendment application was requested in order to clarify core reactivity monitoring requirements in the existing technical. specifications. This amendment would improve the technical specifications for future operation, but is not required for Cycle 11 operation. Since, San Onofre Unit 1 will be permanently shut down after Cycle 11 and the core defueled there will no 4-15
longer be a need for core reactivity monitoring. Therefore, NRC review of this item may be discontinued.
LICENSE EXTENSION TAC #M81806 This Amendment Application proposes to extend the period of the operating license from March 2, 2004 to March 27, 2007 to recapture the period of time that the plant was under construction. San Onofre Unit 1 will be permanently shut down after Cycle 11, therefore, no further action is required by SCE or the NRC.
OFFSITE DOSE CALCULATION MANUAL (ODCM)
TAC #M82259 The NRC transmitted Amendment 145 to San Onofre by letter dated May 15, 1992.
Amendment 145 to the San Onofre Technical Specifications approved the removal of the Radiological Effluent Technical Specifications (RETS).
SCE incorporated the RETS into the San Onofre Unit 1 Offsite Dose Calculation Manual (ODCM) and issued it on June 29, 1992.
SCE considers this item closed based on the above and therefore, no further action on this item is required by SCE or the NRC.
OSRE INSPECTION TAC #M82864 This is an NRC item which requires NRC action to closeout.
4-16 CYCLE 12 FTOL ITEMS WHICH ARE NOT ON TAC LIST The items listed in this enclosure are San Onofre Unit 1 Cycle 12 FTOL items that were not assigned an NRC TAC item number. SCE included these items to inform the NRC of our plans for these projects in view of the impending permanent shutdown of San Onofre Unit 1.
SIMULATOR Cycle 12 FTOL Item 1 This item addresses the San Onofre Unit 1 Simulator Facility Certification required by 10CFR55.45 (b)(2)(iii). In an SCE letter to the NRC dated February 5, 1992 SCE submitted NRC Form 474, "Simulation Facility Certification," for the San Onofre Unit 1 simulator. This certification is
-required-by-10C-FR55.45 for a plant-reference simulator.
SCE considers this item closed based on the above, therefore no further action is required by SCE or the NRC.
TDI DIESEL CRANKSHAFT Cycle 12 FTOL Item 6 This item originates from the TDI diesel crankshaft oil hole cracking problem at San Onofre Unit 1. The NRC issued an SER concerning this problem on November 21, 1989. The SER provided SCE with the option to either (1) replace the existing crankshafts with a superior design, or (2) demonstrate that SCE's eddy current inspection technique is adequate, review and revise the DG oil maintenance procedures to assure oil quality is maintained, and provide evidence that DG start-stop cycles can exclude start-stops for engine speeds less than 200 rpm.
In a February 21, 1990 letter, SCE elected to pursue option (2).
SCE also stated that a response to the SER, which will include appropriate proposed amendments, should be expected by April 30, 1990. In a June 5, 1990 letter, SCE submitted Amendment Application 183 for NRC approval.
This amendment relocated the diesel crankshaft surveillance requirements to an LCO. It also provided additional information as requested in the SER. The NRC issued Amendment 136 approving this amendment application on November 8, 1990.
SCE considers this item closed based on the above, therefore, no further action is required by SCE or the NRC.
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SIS/RECIRC UPGRADE Cycle 12 FTOL Item 13 This item originates from an SCE proposal to modify the Residual Heat Removal (RHR) system to allow it to become a backup to the recirculation portion of the Safety Injection System (SIS).
SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11.
This will nullify the need for the SIS and Recirculation Systems. Therefore, no further action is required by SCE or the NRC.
NUREG-0612 - STEEL PLATING Cycle 12 FTOL Item #15 This item is a result of an SCE analysis of a heavy load being dropped at the north end of the turbine deck and causing potential damage to safe shutdown equipment located below this area. SCE decided to install chain link mesh on the ceiling of the turbine building north extension during the Cycle 12 refueling outage to protect the safe shutdown equipment from concrete spalling.
Since SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11, the need to protect safe shutdown equipment has changed. SCE will not implement this modification, however, we will evaluate our administrative controls for moving heavy loads over the north extension based on the plant being in a shutdown and defueled condition.
SYNCHROCHECK RELAY Cycle 12 FTOL Item #17.
This item implements SCE proposed modifications to prevent out of phase synchronization of the Diesel Generator with the grid.
SCE is planning to permanently shut down San Onofre Unit 1 after Cycle 11.
The testing of the Diesel Generators will be modified as a result of San Onofre Unit 1 being in a defueled condition. Based on this SCE will reevaluate the need for this modification and notify the NRC of its intentions.
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WASTE GAS DECAY TANK Cycle 12 FTOL Item #20 This item originates from the Waste Gas Decay Tank Monitoring Instrumentation Modifications. This modification was completed in June of 1986 as reported by SCE in the Integrated Implementation Schedule (IIS) dated December 27, 1990.
SCE considers this item closed based on the above, therefore, no further action is required by SCE or the NRC.
INSERVICE TEST MODIFICATIONS Cycle 12 FTOL Item #21 This item stems from an NRC order for San Onofre Unit 1 to comply with the ASME Code Section XI requirements for inservice testing by Cycle 12.
SCE has three issues left to resolve for this item:
(1) Installation of flow meters in the SIS pump mini flow
- lines, (2) Modifications to the main feedwater pumps to allow full flow testing, and (3) Modifications to the diesel fuel oil transfer pumps to permit vibration measurements.
SCE will not complete items (1) and (2) above, due the impending permanent shutdown of San Onofre Unit 1 after Cycle 11.
The SIS and the main feedwater pumps are not required for a permanently defueled condition.
Item (3) will be reevaluated to determine the need for this modification with San Onofre Unit 1 in a permanently defueled condition.
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