ML13310A805
| ML13310A805 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/17/1983 |
| From: | Dietch R SOUTHERN CALIFORNIA EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| TAC-54376, NUDOCS 8306220095 | |
| Download: ML13310A805 (26) | |
Text
Southern California Edison Company E
P. 0. BOX 800 2244 WALNUT GROVE AVENUE ROBERT DIETCH ROSEMEAD, CALIFORNIA 91770 TELEPHONE VICEPESENT June 17, 1983 213-572-4144 Mr. H. R. Denton Director, Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Gentlemen:
Subject:
Docket No. 50-206 Plan for Managing Plant Retrofit San Onofre Nuclear Generating Station Unit 1
Reference:
Letter, Robert Dietch, SCE, to H. R. Denton, NRC, dated June 10, 1983 My recent letter to you (see reference) described the actions SCE would be taking with regard to continuation of work on San Onofre Unit 1.
Specifically, it indicated SCE would be developing the Plan for Early Return to Power and the Plan for Managing Plant Retrofit to assist in reducing capital expenditures and improve the capacity factor of the unit. These programs have been discussed with members of your staff. The purpose of this letter is to provide more specific documentation on the Plan for Managing Plant Retrofit and to obtain NRR concurrence on the scope and constraints of our program.
A key aspect of the Plan for Managing Plant Retrofit will be the development of an Integrated Living Schedule (ILS). The concept of an ILS has recently been endorsed in the NRC's statement of policy and planning guidance for 1983 and licensees have been encouraged to explore the implementation of such plans as indicated in Generic Letter 83-20 from D. G. Eisenhut to all licensees, dated May 9, 1983.
The scope of the ILS at San Onofre Unit I will include all backfits scheduled for implementation at the unit including those with regulatory related origins (within the NRC and other national and state regulatory bodies) and those with internal origin. The recently large extent of backfits at the unit have represented a disproportionally large share of SCE's available capital while at the same time have caused the unit's capacity factor to drop precipitously, putting economic viability into question. By implementing an ILS, SCE will be better able to control and predict its expenditures while increasing the reliability and thus economic capability of the facility.
PD66 836,1--7
Mr. H.
June 17, 1983 The scheduling of projects using the ILS framework will be constrained by such parameters as capital expenditures, outage duration, manpower, procurement and engineering lead times, and others as appropriate.
An initial schedule based on these constraints was included in the presentation to NRC management (a copy of the presentation is enclosed for reference). The initial schedule illustrates the number of outages and length of time necessary to implement the list of backfits when the appropriate constraints are used. It should be noted that the initial schedule demonstrated that there were regulatory required backfits with deadlines set by regulation that would not be implemented until after their currently set regulatory dates. Therefore, an essential part of the Plan for Managing Plant Retrofit will be to work with the NRC staff to develop any necessary exemptions. It is SCE's desire to have NRC concurrence on the scope and constraints by mid-July 1983.
Approximately one month after agreement on the scope and constraints, the methodology for the ILS will be developed and submitted. The methodology envisioned for implementation at San Onofre Unit I will be similar to that adopted for the Duane Arnold Energy Center except for the basic emphasis on safety, the length of the schedule and the potentially immediate need to develop exemptions and/or renegotiate schedules on certain regulatory related projects. The ILS to be developed will be different from the initial schedule used in presentations to NRC management in that a more rigorous methodology will be used to give higher priority to the projects with the highest safety significance, the process will be agreed upon with the staff and will be auditable.
It is expected that NRC concurrence with the methodology can be obtained by early September 1983. This will allow SCE to submit an amendment, or other implementation mechanism as appropriate, which will codify the methodology and specify the modifications to be implemented prior to startup and during the following refueling outages. SCE will work with the staff to support formal approval of the ILS by year end which will delineate the requirements for continuing use of the ILS and determine the schedule for the return to service of San Onofre Unit 1.
We look forward to working with the staff on this plan. Please contact me if you desire further information.
Very truly yours, Enclosure cc: J. B. Martin, Regional Administrator, NRC Office of I&E, Region V
e Mosure PLAN FOR MANAGING PLANT RETROFIT SAN ONOFRE UNIT 1
INTEGRATED BACKFIT PROGRAM o MANAGE RESOURCES EFFICIENTLY CAPITAL EXPENDITURES CAPACITY FACTOR MANPOWER o ACHIEVE STABILITY AND PREDICTABILITY OF PROCESS o
INTEGRATE REGULATORY COMMITMENTS (INCLUDING SEP), PLANT BETTERMENT AND OUTAGE MANAGEMENT
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 1
-1000 TORNADO & HIGH ENERGY LINE BREAKS
-900 FIRE PROTECTION, SINGLE FAILURE CRITERIA 0
FIRE PROTECTION, DEDICATED SIS,
-800 9
EBV VALVE ACTUATOR REPLACEMENT 0
SEISMIC UPGRADE, DRAWING
-700 x
VERIFICATION, ELECTRICAL EQUIPMENT QUALIFICATION Li
-600 :
TMI, FIRE PROTECTION SPHERE ENCLOSURE, Li SPA, TMI, STEAM
-o500 x Li GENERATOR SLEEVING WMA 400 Legend
-300 2 FORECAST G
COMMITTED 200 ORIGINAL PLANT COST
-100 1968 1981 1982 1983 1984 1985 1986 YEAR OF OPERATION
SCE PROJECT COSTS
$ X MILLION EXAMPLE: TYPICAL BACKFIT WORK ORDER CONTRACTOR COSTS
$102.2 SCE CONSTRUCTION MANAGEMENT, START-UP, QA, DOCUMENT CONTROL, PROCUREMENT, ACCOUNTING, SYSTEMS AND PROCEDURES, WAREHOUSING AND FIRE WATCHES 45.8 148.0 SCE STATION LIAISONS, HEALTH PHYSICS, SECURITY AND LICENSING 17.0 BASE WORK ORDER LEVEL COSTS (100%)
165.0 OVERHEADS:
o DIVISION OVERHEADS:
4.6 OVERHEAD COSTS INCURRED WITHIN THE VARIOUS DIVISIONS AND DEPARTMENTS OF THE COMPANY o MISCELLANEOUS CONSTRUCTION EXPENSE:
(MCE) 12.8 COSTS FOR SCE ADMINISTRATIVE SERVICES WHICH CANNOT BE READILY IDENTIFIED AGAINST A SPECIFIC PROJECT.
INCLUDED IN THESE COSTS ARE:
SCE'S CONTRIBUTION TO EMPLOYEES' BENEFITS, UPKEEP OF OFFICE BUILDING, SALARIES OF SCE OFFICERS, ETC.
o ALLOWANCE FOR FUNDS USED DURING CONSTRUCTION (AFUDC):
24.6 INTEREST PAID BY SCE ON THE MONIES BARROWED OR USED DURING THE PROJECT LIFE PRIOR TO A FACILITY BEING PUT INTO OPERATION TOTAL PROJECT COSTS:
207.0
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 1 ANNUAL CAPACITY FACTORS 100 80 200 Co O
60 20 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 982 YEAR OF OPERATION
SAN ONOFRE UNIT 1 OPERATING HISTORY Capacity Major Year Factor(%
Modifications Investments (million) 68 34 Base Plant 88 69 69 70
.81 71 88 72 75 73 60 74 84 75 86 Fences, Alarms, Radiation Monitoring.
2 76 66 High Energy Lines (2M), Safety Equipment (2M) 4 77 61 Standby Power (approximately 36M), Sphere Enclosure (apprximately 37M) 73 78 70 Floods (2M), Overpressure (2M), SFA (2M), Misc. (9M) 15 79 88 Site Security 11 80 21 Security Processing 6
81 20 Fire Protection -
Phase 1 (18M) 142 Steam Generator (72M), Misc. (50M) 82 13 TMI (61M), Fire Protection Phase 2 (7M), Misc.. (8M) 76 Shutdown February 27, 1982 for Seismic Backfit -
Startup Uncertain
UNDERSTAND TOTALITY OF WORK 0
EXISTING REGULATORY COMMITMENTS SEISMIC UPGRADE ENVIRONMENTAL QUALIFICATION FIRE PROTECTION APPENDIX R SYSTEMATIC EVALUATION PROGRAM BACKFIT DEDICATED SAFETY INJECTION AND FEEDWATER SYSTEMS INSTRUMENTATION SYSTEM FOR DETECTION OF INADEQUATE CORE COOLING CONTROL ROOM DESIGN REVIEW SAFETY PARAMETER DISPLAY SYSTEM REGULATORY GUIDE 1.97 INSTRUMENTATION AUXILIARY FEEDWATER SYSTEM SAFETY GRADE UPGRADE AND THIRD TRAIN CONTROL ROOM HABITABILITY, HVAC UPGRADE POST ACCIDENT SAMPLING SYSTEM OXYGEN AND CHLORIDE MONITORING PARTICULATE EFFLUENT MONITORING SYSTEM PLATE-OUT CONCERN HEAVY LOADS LIFT RIGS AND TURBINE DECK SPALLING PROTECTION SYSTEM VOLTAGE DEGRADATION 4 KV UNDERVOLTAGE RELAYS RADIOLOGICAL EFFLUENT MONITORING SYSTEMS PURGING AND VENTING SYSTEM VALVE REPLACEMENT AND DEBRIS SCREEN PRESSURIZER PORV BLOCK VALVES ECCS SINGLE FAILURE UPGRADE DIESEL GENERATOR FANS SIS ANNUNCIATOR WINDOWS ISOLATION VALVES FOR STEAM GENERATOR SAMPLE AND BLOWDOWN LINES CONTAINMENT ISOLATION RELAYS SIS PUMP SUCTION NOZZLES G & W (EFCOMATIC) ACTUATORS REGULATED INSTRUMENT BUSES NITROGEN SUPPLY FOR PORV'S AND FCV'S 1115 D, E AND F UPGRADE TO SAFETY GRADE CV 525 AND 527 VALVE SEATS SEPARATE POWER SUPPLY TO LETDOWN ISOLATION VALVES INLAND METEOROLOGICAL TOWER SOLIDIFIED RESIN STORAGE BUILDING AND TRANSPORTATION EQUIPMENT WASTE GAS DECAY TANK SYSTEM CORRODED SAFETY RELATED AND NON-SAFETY RELATED PIPING COMPONENT COOLING WATER HEAT EXCHANGER SERVICEABILITY SV-99 REPLACE ACTUATION TO RELIABLE CHANNEL TURBINE LAB DRAINS CONDENSATE STORAGE TANK FLOODING POTENTIAL HEALTH PHYSICS BUILDING REACTOR COOLANT PUMP TRIP
0 STATION BETTERMENT MODIFICATION TO THE 125-VDC SYSTEM UPGRADE SAFETY RELATED AND NON-SAFETY RELATED POWER SUPPLY SALTWATER COOLING VALVES POV 1-10 ELECTRICAL POWER BUSES CHEMICAL AND VOLUME CONTROL SYSTEM VALVES MOV-LCV-1100 B, C & D STEAM PIPE EROSION CONTROL ROOM IMPROVEMENT BATTERY NO.
1 CATHODIC PROTECTION LEADS UPGRADE BALANCE CF SAFETY RELATED SNUBBERS REPLACE SIS RECIRCULATION LINE BORON ANALYZER PROCESS PH METER SLUDGE REMOVAL TRAP INLET PRESSURE GAUGES ON RHR PUMPS CONTAINMENT SUMP LEVEL CONTROLLER PERMANENT DOMESTIC WATER LINE TO UNIT 1 DEMINERALIZED WATER CROSS TIE TELECOMMUNICATIONS NORTH GUARD TOWER VIDEO STATION SERVICE TRANSFORMER SYSTEM DESCRIPTION BREATHING AIR FOR SPHERE INSTALL PERMANENT WALKWAY HALON AWS COMMUNICATIONS ROOM 12 KV CONSTRUCTION POWER SYSTEM SEQUENCER LOGIC BOARDS LOCAL ASHCROFT GAUGES CONTROL ROOM INSTRUMENT RACKS 1-5 FLUX MAPPING SYSTEM NUISANCE ALARMS BATTERY CHARGER HYDRAZINE LOW FLOW AND CONTAINMENT SUPPLY SYNCHRO CHECK RELAY PROTECTION STEAM GENERATOR MANWAY TENSIONER POWER SUPPLY FOR DECONTAMINATION SYSTEMS -
ELECTRO POLISHER INSTALL RACEWAY IN SPENT FUEL AREA RADIATION DETECTORS OUTER CIRCLE TEMPERATURE AVERAGE CIRCUITS SECONDARY CHEMISTRY MONITORING GLAND SEAL EXHAUST SEISMIC MONITORING INSTRUMENTATION OPERATIONAL RADIATIO 1
NEI
,RING SYSTEM
SAN ONOFRE BACKFIT PLANNING PROCESS SELECTION OF CURRENT OUTAGE PROJECTS BACKFIT ORIGIN CONCEPTUAL PLAN 1
LICENSING COST, SCOPE, PRIORITIZE DETERMINE SCHEDULE, ETC.
PROJECTS OUTAGE FOR o 10 CFR IMPLEMENTATION o ORDERS o DESCRIPTION o LICENSING o BULLETINS OF CHANGES o STATION o CURRENT OUTAGE o LER's o FURECASTED o PROJECT o NEXT OUTAGE o OTHERS MILESTONES o FUTURE o FUTURE WORK LIST STATION o RESOURCE FORECASTS o CONTRACTOR o PLANT BETTERMENT PREQUALIFICATION o COMPLIANCE o ORDER-OF-MAGNITUDE b OTHERS COST EST.
SAN ONOFRE BACKFIT PLANNING PROCESS IMPLEMENTATION OF CURRENT OUTAGE PROJECTS PRELIMINARY FINAL IMPLEMENTATION, SCOPE, COST A SCOPE, 0 SAFETY
- TURNOVER, SCHEDULE SCHEDULE REVIEW OPERATION o QUANTIFICATION o NRC COMMITMENTS o BAR CHARTS o WORK ASSIGNMENTS o LONG LEAD MATERIAL o CRITICAL PATH SCHEDULING o BUDGET ESTIMATE o DRAWINGS AND SPECS.
o MISCELLANEOUS MATERIAL
INTEGRATED BACKFIT PROGRAM STATUS o
INITIAL SCHEDULE IDENTIFIED PROJECTS (TOTALITY OF WORK)
SCHEDULE MANAGEMENT (18 MONTH CYCLE.- 3 MONTH OUTAGE)
PLANT BETTERMENT REGULATORY COMMITMENTS INTEGRATION INITIAL SCHEDULE o
PRESENTATIONS TO NRC MANAGEMENT o
SAFETY SIGNIFICANCE SCHEDULE EMPHASIZE SAFETY SIGNIFICANCE
INITIAL SCHEDULE LONG TERM PLANT MODIFICATION UPGRADE SCHEDULE OUTAGE SCHEDULE CYCLE IX 01/01/85 -
03/31/85 CYCLE X 10/01/86 -
12/31/86 CYCLE XI 07/01/88 -
09/30/88 CYCLE XII 04/01/90 -
06/30/90
INITIAL SCHEDULE CYCLE IX REFUELING OUTAGE MODIFICATIONS O
COMPLETE SEISMIC UPGRADE O
PARTIAL ENVIRONMENTAL QUALIFICATION 0
PARTIAL SYSTEMATIC EVALUATION PROGRAM O
SYSTEM VOLTAGE DEGRADATION 4 KV UNDERVOLTAGE RELAYS O
PRESSURIZER PORV BLOCK VALVES O
DIESEL GENERATOR FANS O
PARTICULATE EFFLUENT MONITORING SYSTEM PLATE-OUT CONCERN 0
ISOLATION VALVES FOR STEAM GENERATOR SAMPLE AND BLOWDOWN LINES O
AUXILIARY FEEDWATER SYSTEM SAFETY GRADE UPGRADE O
CONTAINMENT ISOLATION RELAYS 0
SIS ANNUNCIATOR WINDOWS
INITIAL SCHEDULE CYCLE X REFUELING OUTAGE MODIFICATIONS O
PARTIAL FIRE PROTECTION APPENDIX R 0
PARTIAL SYSTEMATIC EVALUATION PROGRAM O
COMPLETE ENVIRONMENTAL QJALIFICATION O
POST ACCIDENT SAMPLING SYSTEM OXYGEN AND CHLORIDE MONITORING O
CONTROL ROOM HABITABILITY HVAC UPGRADE O
ECCS SINGLE FAILURE UPGRADE O
DEDICATED SIS AND FEEDWATER SYSTEMS 0
SIS PUMP SUCTION NOZZLES
INITIAL SCHEDULE CYCLE XI REFUELING OUTAGE MODIFICATIONS O
COMPLETE FIRE PROTECTION APPENDIX R 0
PARTIAL.SYSTEMATIC EVALUATION PROGRAM O
PARTIAL INSTRUMENTATION SYSTEM FOR DETECTION OF INADEQUATE CORE COOLING 0
PARTIAL REQUIREMENTS FOR EMERGENCY RESPONSE CAPABILITY 0
NITROGEN SUPPLY FOR PORV'S AND FCV'S 1115 D, E F UPGRADE TO SAFETY GRADE 0
G & W (EFCOMATIC) ACTUATORS O
UPGRADE BALANCE OF SAFETY RELATED SNUBBERS 0
REGULATED INSTRUMENT BUSES
INITIAL SCHEDULE CYCLE XII REFUELING OUTAGE MODIFICATIONS O
PARTIAL SYSTEMATIC EVALUATION PROGRAM O
PARTIAL REQUIREMENTS FOR EMERGENCY RESPONSE CAPABILITY 0
PARTIAL INSTRUMENTATION SYSTEM FOR DETECTION OF INADEQUATE CORE COOLING O
RADIOLOGICAL EFFLUENT MONITORING SYSTEMS O
HEAVY LOADS LIFT RIGS AND TURBINE DECK SPALLING PROTECTION O
REPLACE SIS RECIRCULATION LINE 0
CV 525 AND 527 VALVE SEATS
INITIAL SCHEDULE MODIFICATIONS IF NOT COMPLETED BY CYCLE XII REFUELING OUTAGE WOULD BE SCHEDULED AFTER THAT O
COMPLETE SYSTEMATIC EVALUATION PROGRAM O
COMPLETE INSTRUMENTATION SYSTEM FOR DETECTION OF INADEQUATE CORE COOL ING O
COMPLETE REQUIREMENTS FOR EMERGENCY RESPONSE CAPABILITY O
INLAND METEOROLOGICAL TOWER O
MODIFICATION TO THE 125-VDC SYSTEM O
CORRODED SAFETY RELEATED AND NON-SAFETY RELATED PIPING O
BATTERY NO. 1 O
SALTWATER COOLING VALVES POV 1-10 O
BORON ANALYZER O0 PROCESS PH METER O
SLUDGE REMOVAL TRAP O
IN'LET PRESSURE GAUGES ON RHR PUMPS O
CONTAINMENT SUMP LEVEL CONTROLLER O
STEAM PIPE EROSION O
PERMANENT DOMESTIC WATER LINE TO UNIT 1 O
DEMINERALIZED WATER CROSS TIE O
TELECOMMUNICATIONS o
NORTH GUARD TOWER.VIDEO O
STATION SERVICE TRANSFORMER 0
SYSTEM DESCRIPTION O
BREATHING AIR FOR SPHERE 0
ELECTRICAL POWER BUSES O
INSTALL PERMANENT WALKWAY O
CONTROL ROOM IMPROVEMENT O
HALON AWS COMMUNICATION ROOM O
12.KV CONSTRUCTION POWER SYSTEM O
SEPARATE POWER SUPPLY TO LETDOWN ISOLATION VALVES O
UPGRADE SAFETY RELATED AND NON-SAFETY RELATED POWER SUPPLY O
SEQUENCER LOGIC BOARDS 0-LOCAL ASHCROFT GAUGES O
SOLIDIFIED RESINS STORAGE BUILDING AND TRANSPORTATION EQUIPMENT 0
WASTE GAS DECAY TANK SYSTEM O
COMPONENT COOLING WATER HEAT EXCHANGER SERVICEABILITY o
SV-99 REPLACE ACTUATION TO RE.I-ABLE CHANNEL 0
TURBINE LAB DRAINS O
CONDENSATE STORAGE TANK FLOODING POTENTIAL O
HEALTH PHYSICS BUILDING O
CHEMICAL AND VOLUME CONTROL SYSTEM VALVES MOV-LCV 11008, C AND D 0
CONTROL ROOM INSTRUMENT RACKS 1-5 O
FLUX MAPPING SYSTEM O
NUISANCE ALARMS BATTERY CHARGER, HYDRAZINE LOW FLOW AND CONTAINMENT SUPPLY O
SYNCHRO CHECK RELAY PROTECTION O
STEAM GENERATOR MANWAY TENSIONER 0
POWER SUPPLY FOR DECONTAMINATION SYSTEM. -- ELECTRO POLISHER 0
INSTALL RACEWAY IN SPENT FUEL AREA 0
RADIATION DETECTION OUTER CIRCLE O
TEMPERATURE AVERAGE CIRCUITS O
SECONDARY.CHEMISTRY MONITORING 0
GLAND SEAL EXHAUST O
SEISMIC MONITORING INSTRUMENTATION
SAFETY BASED INTEGRATED SCHEDULE INPUTS O SAFETY SIGNIFICANCE 0 CONSTRAINTS ON IMPLEMENTATION U 10% PLANT BETTERMENT O JUSTIFICATION FOR DEFERRAL O INTEGRATION
INTEGRATED SCHEDULE SAFETY SIGNIFICANCE PARAMETERS O SYSTEM IMPROVEMENT IMPACT ON RELIABILITY IMPACT ON FAILURE MODES O SYSTEM IMPORTANCE CRITICAL FUNCTIONS DOMINANT SEQUENCES METHODOLOGY O RELIABILITY ANALYSIS DATA FROM PRIOR PRA'S O DETERMINISTIC ANALYSIS 0 INSIGHTS FROM RELATED PRA'S
INTEGRATED SCHEDULE CONSTRAINTS ON IMPLEMENTATION 0
SCHEDULAR CONSTRAINTS O
OUTAGE DURATION O
MANPOWER CAPABILITY O
CAPITAL EXPENDITURES 0
OTHERS
INTEGRATED SCHEDULE JUSTIFICATION FOR DEFERRAL O
SAFETY PLATEAU ACHIEVED 0
ALTERNATIVES AVAILABLE O
COMPENSATING MEASURES 0
OVERALL SAFETY SIGNIFICANCE
INTEGRATED SCHEDULE UPDATING O INTEGRATION OF NEW REGULATORY REQUIREMENTS O FIRM SCHEDULE CHANGE IN OUTAGE DOES NOT AFFECT SCHEDULE O OPTIMIZATION PROCESS IMPROVED SAFETY PRIORITIZATION 0 NRC APPROVAL
INTEGRATED SCHEDULE CONCLUSION 0 NECESSARY FOR STABILITY AND PREDICTABILITY O EMPHASIZES SAFETY SIGNIFICANCE 0 REQUIRES NRC ENDORSEMENT
INTEGRATED SCHEDULE IMPLEMENTATION PLAN ACTION APPROXIMATE DATE SCE SUBMIT LETTER OF INTENT FOR JUNE 10, 1983 INTEGRATED SCHEDULE INCLUDING DETAILS ASSOCIATED WITH LEVEL OF WORK NRC CONCURRANCE WITH LEVEL OF WORK JUNE 26, 1983 SCE SUBMIT SAFETY BASED INTEGRATED JULY 29, 1983 SCHEDULE METHODOLOGY NRC CONCURRANCE WITH SAFETY BASED AUGUST 26, 1983 INTEGRATED SCHEDULE METHODOLOGY SCE SUBMIT AMENDMENT APPLICATION NOVEMBER 15, 1983 WITH SAFETY BASED.INTEGRATED SCHEDULE NRC ISSUE AMENDMENT TO OPERATING DECEMBER 31, 1983 LICENSE IMPLEMENT SAFETY BASED INTEGRATED SCHEDULE