ML13310A994
| ML13310A994 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 09/27/1983 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Mertens J AFFILIATION NOT ASSIGNED |
| References | |
| LSO5-83-09-039, LSO5-83-9-39, NUDOCS 8310050091 | |
| Download: ML13310A994 (45) | |
Text
Distri bution September 27, 1983 fck i~NRC P DR Local PDR ORB #5 Reading NSIC DCrutchfield HSmith WPaulso.n Mr. John Mertens OELD 3109 South El Camino Real ELJordan San Clemente, California 92672 JMTaylor ACRS Co
Dear Mr. Mertens:
6sman
SUBJECT:
SEISMIC UPGRADING-SAN ONOFRE, UNIT NO.
1 Your letter dated August 22, 1983 addressed to Mr. J. B. Martin, Regional Administrator, Region V, U. S. Nuclear Regulatory Commission, has been referred to me for response.
Your letter requested (1) "a binding state ment" itemizing both the remaining seismic upgrading requirements that must be completed before start-up and any other upgrading requirements whose completion is mandatory before start-up, and (2) a list of other upgrading requirements not mandatory but adviseable and a timetable for their com pletion.
With regard to the issues that need to be addressed prior to start-up from the current outage, I am enclosing two orders (Enclosure 1 and 2) issued by there NRC relating to seismic upgrading and to certain.post-TMI related issues.
In addition, there are certain fire protection features that must be installed prior to start-up.
By letters dated June 10 and June 17, 1983, Southern California Edison indicated that they intend to submit a Plan for Early Restart for NRC review and approval.
It is our understanding that this plan will detail the licensee's proposal with regard to those additions/
modifications to be completed prior to restart. When this plan is received it will be reviewed by the NRC staff and the acceptability of the proposal will be determined.
Southern California Edison Company is also developing a Plan for Managing Plant Backfit as discussed in their June 17, 1983 letter (enclosure 3).
The enclosure to this letter provides an initial listing of modifications proposed by the licensee, a preliminary schedule, their estimates of the costs. The NRC is currently reviewing the licensee's proposed methodology for priortizing the various modifications submitted by letter dated September 2, 1983. The final schedule for implementing the safety-related modifications will be reviewed by the NRC to determine whether it is acceptable.
I trust that this letter provides the information you requested.
Sincerely, 8310050091 820927 PDR ADOCK 05000206 Original signed by H
PDR Dennis M. Crutchfield, Chief Operating Reactors Branch #5 Division of Licensing OFF4CE
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//*83-*
NRC FORM 318 (10-80) NRCM 0240 OFFICIAL RECORD COPY USGPO: 1981-335-960
Eo
.UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 September 27, 1983 LSO5-83-09-039 Mr. John Mertens 3109 South El Camino Real San Clemente, California 92672
Dear Mr. Mertens:
SUBJECT:
SEISMIC UPGRADING-SAN ONOFRE, UNIT NO. 1 Your letter dated August 22, 1983 addressed to Mr. J. B. Martin, Regional Administrator, Region V, U. S. Nuclear Regulatory Commission, has been referred to me for response. Your letter requested (1) "a binding state ment" itemizing both the remaining seismic upgrading requirements that must be completed before start-up and any other upgrading requirements whose completion is mandatory before start-up, and (2) a list of other upgrading requirements not mandatory but adviseable and a timetable for their com pletion.
With regard to the issues that need to be addressed prior to start-up from the current outage, I am enclosing two orders (Enclosure 1 and 2) issued by there NRC relating to seismic upgrading and to certain post-TMI related issues. In addition,. there are certain fire protection features that must be installed prior to start-up. By letters dated June 10 and June 17, 1983, Southern California Edison indicated that they intend to submit a Plan for Early Restart for NRC review and approval. It is our understanding that this plan will detail the licensee 's proposal with regard to those additions/
modifications to be completed prior to restart.
When this plan is received it will be reviewed by the NRC staff and the acceptability of the proposal will be determined.
Southern California Edison Company is also developing a Plan for Managing Plant Backfit as discussed in their June 17, 1983 letter (enclosure 3).
The enclosure to this letter provides an initial listing of modifications proposed by the licensee, a preliminary schedule, their estimates of the costs. The NRC is currently reviewing the licensee's proposed methodology for priortizing the various modifications submitted by letter dated September 2, 1983.; The final schedule for implementing the safety-related modifications will be reviewed by the NRC to determine whether it is acceptable.
I trust that this letter provides the information you requested.
Sincerely, Dennis M. Crutchfie, Chief Operating Reactors Branch #5 Division of Licensing
Enclosures:
As stated
7590-01 ENCLOSURE 1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
SOUTHERN CALIFORNIA EDISON COMPANY AND SAN DIEGO GAS AND ELECTRIC
)
Docket No. 50-206 COMPANY
)
(San Onofre Nuclear Generating
)
Station, Unit No. 1)
)
ORDER CONFIRMING LICENSEE COMMITMENTS ON SEISMIC UPGRADING The Southern California Edison Company (SCE) and the San Diego Gas and Electric Company (the licensees) hold Provisional Operating License No.
DPR-13, which authorizes Southern California Edison Company to operate the San Onofre Nuclear Generating Station, Unit No. 1 (the facility) at power levels not in excess of 1347 megawatts (thermal) rated power. The facility, which is located at the licensees' site in San Diego County, California, is a pressurized water reactor (PWR) used for the commercial generation of electricity.
- 11.
The San Onofre Nuclear Generating Station, Unit No. I, is one of eleven older operating plants that are part-of the Systematic Evaluation Program (SEP).
The purpose of the SEP is to evaluate these plants against current licensing criteria to provide an integrated and balanced decision on backfitting.
One of the SEP topics is the reevaluation of the capability of San Onofre Unit 1 to withstand seismic events.
7590-01 The San Onofre Unit 1 was licensed by the Atomic Energy Commission on March 27, 1967. In the original seismic design, components, systems and structures which were designated as important to the nuclear safety of the plant were designated Seismic Category A. Specifically, s(tructures, systems and components associated with the reactor coolant system, boron injection, safety injection system, and residual heat removal were designed as Seismic Category A. The design basis used for Seismic Category A was what in today's terminology would be consistent with the 0.25g Housner Spectra Operating Basis Earthquake (OBE) and the 0.5g Housner Spectra Safe Shutdown Earthquake (SSE).
The Turbine Building extensions, which contain Seismic Category A systems and components, were designated Seismic Category B and designed to a maximum ground acceleration of 0.2g (static force criteria). Seismic Category B is a classification specified by the licensees for components, systems, and structures that are important to the continuity of power generation or whose contained activity is such that release would not constitute a hazard.
Since the original plant was constructed, various structures and systems have been added to the plant. The licensees designed these new items to higher seismic levels to be consistent with the criteria being applied in the design of Units 2 and 3. Specifically, the sphere enclosure building and the diesel gener ator and its associated structures, system and components were designed to a 0.67g modified Newmark response spectra (more conservative than the Housner Spectra).
In 1973, the licensees initiated a program to reevaluate and modify as:
necessary the capability of San Onofre Unit 1 to withstand seismic events.
The criteria for this program were the 0.67g Housner Spectra. The first phase of this program consisted of reevaluating (1) systems and components to -prevent
7590-01
-3 a design basis loss of coolant accident, including the main reactor coolant loop and Nuclear Steam Supply System (NSSS) components, and (2) the reactor building and the containment sphere. Based upon their rearalyses, the licensees concluded that the containment sphere, the reactor building and structural steel framing have resistance capacities in excess of those required to meet 0.67g Housner Spectra. As a result, the licensees concluded that modifications to these structures were not necessary.
However, support modifications in the form of additional seismic restraints were required to meet allowable stresses. for several of the larger NSSS components which were base supported. These modifications were implemented during an outage in 1976-1977.
Following initiation of the SEP in 1978, subsequent phases of the seismic reevaluation program were incorporated into the SEP. This program is proceeding in three phases:
(1) reevaluation of balance-of-plant struc tures; (2) reevaluation of piping and mechanical equipment required to shut down the plant; and (3) reevaluation of piping and mechanical equipment required to mitigate the consequences of accidents. The earthquake input being used for this program is the 0.67g Housner response spectra.
The NRC staff issued letters dated August 4, 1980 and April 24, 1981 to the licensees requesting details of the seismic reevaluation program including the scope of review, the evaluation criteria, the schedule for completion and justification for continued operation in the interim until completion of the seismic reevaluation program. The licensees responded by letters dated September 24, 1980, February 23, April 24, July 7, August 11, September 28, October 5, 1981 and October 19, 1981.
The NRC
.7590-01
-4 Staff evaluated the licensee's responses and issued a Safety Evaluation Report of the Interim Seismic Adequacy for San Onofre Unit 1 dated November 16, 1981.
This report addressed the licensees' conclusion that continued operation is acceptable in the interim until the seismic reevaluation, and any necessary upgrading, is complete. The NRC staff agreed with the licensees' April 28, 1980 basis for continued operation for those systems, structures, and components which were originally designed to meet the 0.5g Housner Spectra as ground motion input; however, the staff concluded that certain modifications were necessary, in the near term, to upgrade the North Turbine Building Extension and the West Feedwater Heater Platform which were originally designed to 0.2g static.
The licensees made modifications to upgrade these structures during the current outage which began on February 27, 1982.
At a meeting with the NRC staff on May 3, 1982, the licensees presented the results of their reevaluation, using the 0.67g Housner Spectra, of the balance of plant mechanical equipment and piping required to shutdown the plant. The results of the licensees' evaluation as documented in their April 30, 1982 sub mittal showed high stress values for certain equipment, piping and their supports.
These high stress values caused the NRC staff to raise a concern as to whether existing piping, pipe supports and mechanical equipment including it.s anchorage meet the original licensing basis for San Onofre Unit 1. This concern was the subject of a meeting between the licensees and the NRC staff on May 20, 1982.
At the end of this meeting, the NRC staff concluded that the licensees needed to provide information that demonstrates that the facility meets its licensed design basis before the plant would be permitted to restart from the current outage.
7590-01
-5 III.
By letter dated June T5, 1982 as supplemented by letter dated June 24, 1982, the licensees stated that they intend to complete the analyses and make modifica tions to the facility to meet the 0.67g Housner Spectra ground motion rather than to demonstrate that the facility meets its original 0.5g Housner Spectra design basis. The licensees committed to extend the present outage until the modifications are completed to upgrade San Onofre Unit No. 1 to 0.67g Housner Spectra ground motion. In view of the foregoing information regarding the seismic capability of the facility, I have determined that the licensees' commitment is required in the interest of the public health and safety and should, therefore, be-confirmed by an immediately effective Order.
IV.
Accordingly, pursuant to Sections 103 and 161i of the Atomic Energy Act of 1954, as amended, and the Commission's regulations in 10 CFR Parts 2 and 50, IT IS HEREBY ORDERED, EFFECTIVE IMMEDIATELY, THAT the licensees shall:
Maintain San Onofre Unit 1 in the shutdown condition until modifications described in their submittal dated June 15, 1982 as supplemented by letter dated June 24, 1982 are com pleted and NRC approval is obtained for restart.
V..
The licensees may request a hearing on this Order within 20 days of the date of publication of this Order in the Federal Register. A request for a hearing shall be addressed to the Director, Division of Licensing, Office of Nuclear Reactor
75,90-01
-6 Regulation, U. S. Nuclear Regulatory Commission, Washington, D. C. 20555.
A copy shall also be sent to the Executive Legal Director at the same address.
A REQUEST FOR HEARING SHALL NOT STAY THE IMMEDIATE EFFECTIVENESS UF THIS ORDER.
If a hearing is requested by the licensees, the Commission will issue an Order designating the time and place of any such hearing. Resumption of oper ation on terms consistent with this Order need not be stayed by the pendency of any proceeding on this Order.
If a hearing is held concerning this Order, the issue to be considered at the hearing shall be whether, as set forth in Section IV of this Order, the licensees should maintain San Onofre Unit 1 in the shutdown condition until modifications described in their submittal dated June 15, 1982 as supplemented by letter dated June 24, 1982 are completed and NRC approval is obtained for restart.
This Order is effective upon issuance.
OR THE NUCLEAR REGULATORY COMMISSION C e Ei e'nhut, Director Division of L'censing Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland this 11th day of August, 1982.
K).()ENCLOSURE 2 UNITED[ ST1ATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 March 14, 1983 Docket No.
2 Mr. R. Dietch, Vice President Nuclear Engineering and Operations.
Southern California Edison Company 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770
Dear Mr. Dietch:
SUBJECT:
ORDER CONFIRMING LICENSEE COMMITMENTS ON POST-TMI RELATED ISSUES (GENERIC LETTERS 82-05 AND 82-10)
San Onofre Nuclear Generating Station, Unit No. 1 The Ccmmission has issued the enclosed Order confirming your commitments to implement those post-TMI related items set forth in NUREG-0737 for which the staff requested completion on or after July 1, 1981.
This Order is based on comitments contained in. your letters responding to the NRC's Generic Letter 05 and 82-10 dated March 17, 1982 and May 5, 1982, respectively.
The Order references your letters and, in its Attachments, contains lists of the applicable NUREG-0737 items with your schedular commitment.
As discussed in the Order, several of the items listed in Generic Letter 82-10 will be handled outside of this Order.
The Commission's intention when it issued NUREG-0737 was that items would be cocoleted in accordance with the staff's recommended schedule.
However, our evaluatIon or your proposed schedule exceptions. concludes that the proposed delays are acceptable.
Among other things, the Order requires implementation of these items in accordance with your proposed schedule.
Some of the items set forth in the Attachments to the Order are subject to post i ementation review and inspection. Our post implementation review and/or the development of Technical Specifications may identify alterations to your method of imlementing and maintaining the requirements.
Any identified alterations will be the subject of future correspondence.
Mr. R. Dietch
- 2
-March 4,
9H3 A coPy of. this Order is being filed with the Office of the.Federal Register for publication.
Sincerely, Dennis M. Crutchfiel Chief Operating Reactors Branch #5 Division of Licensing
Enclosure:
Order cc w/enclosure:
See next page
M'-'Di etch 3 -
arch 14, 1983 cc Charles R. Kocher, Assistant General Counsel James ieoletto, Esquire.
Southern California Edison Company Post Office Box 800 Rosemead, California 91770 David R. Pigott Orrick, Herrington & Sutcliffe 600.Montgomery Street San Francisco, California 94111 Harry B. Stoehr San Diego Gas & Electric Company P. 0. Box 1831 San Diego, California 92112 Resident Inspector/San Onofre NPS c/o U. S. NRC P. 0. Box 4329 San Clemente, California 92672 Mayor City of San Clemente San Clemente, California 92672 Chairman Board of Supervisors County of San Diego San Diego, California 92101 California Department of Health ATTN:
Chief, Environmental Radiation Control Unit Radiological Health Section 714 P Street, Room 498 Sacramento, California 95814 U. S. Environmental Protection Agency Recion IX-Office AT N:
Recional Radiation Representative 215 Freemont Street San Francisco, California 94111 Robert H. Engelken, Regional Administrator Nuclear Regulatory Commission, Region V 1450 '.aria Lane Walnut Creek, California 94596
(7590-01 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMTISSION In the Matter of
)
SOUTHERN CALIFORNIA EDISON COMPANY AND SAN DIEGO GAS AND ELECTRIC
)
Docket No. 50-206 COMPANY (San Onofre Nuclear Generating Station, Unit 1)
ORDER CONFIRMING LICENSEE COMMITMENTS ON POST-TMI RELATED ISSUES I.
Southern California Edison Company (SCE) and San Diego Gas and Electric Company (the licensees) are the holders of Provisional Operating License No. OPR-13 which authorizes the operation of the San Onofre Nuclear Generating Station, Unit 1 (the facility) at steady-state power levels not in excess of 1347 megawatts thermal.
The facility is a pressurized water reactor (PWR) located in San Diego County, California.
II.
Following the accident at Three Mile Island Unit No. 2 (TMI-2) on March 28,
- 1979, the Nuclear Regulatory Commission (NRC) staff developed a number of proposed requirements to be implemented on operating reactors and on plants under construction. These requirements include Operational Safety, Siting and Design, and Emergency Preparedness and are intended to provide substantial additional protection in the operation of nuclear facilities based on the experience from the accident at TMI-2 and the official studies and
( 7590-01)
-2 investicaticns of the acc-ident.
The staff's proposed requirements and schedule for implementation are set forth in NUREG-0737, Clarification of TMI Action Plan Requirements." Among these requirements are a number of items, consisting of hardware modifications, administrative procedure implementation and specific information to be submitted by the licensee, scheduled to be completed on or after July 1, 1981.
On March 17, 1982, a letter (Generic Letter 82-05) was sent to all licensees of operating power reactors for those items that were scheduled to be implemented from July 1, 1981 through March. 1, 1982.
Subsequently, On May 5, 1982, a letter (Generic Letter 82-10) was also sent to all licensees of operating power reactors for those items.that were schedule for implementation after March 1, 1982. These letters are hereby incorporated by reference. In these letters-each licensee was requested to furnish within 30 days pursuant to 10 CFR 50.54(f) the following information for items which the staff had proposed for completion on or after July 1, 1981:
(1) For applicable items that have been completed, confirmation of completicn and the date of completion, (2) For items that have not been completed, a specific schedule for implementation, which tie licensee committed to meet, and (3) Justification for delay, demonstration of need for the proposed schedule, and a description of the interim compensatory measures being taken.
III.
Southern California Edison Company (SCE) responded to Generic Letter 82-05 by letters dated April 16, October 12, October 14, November 19, 132, ahd February 15., 1983. SCE responded to the Generic Letter 82-10
(7590-01
-3 by letters dated June 4, -1982 October 12, 1932, november 19, -192 and February 16, 1983. In these submittals, SCE confirmed that some of the items identified in the Generic Letters had been completed and made commitments to complete the remainder. The attached Tables summarizing SCE's schedular comitments or status were developed by the staff from the Generic Letters and the information provided by SCE.
There are several items in Generic Letter 82-10 that as noted in Attachment 2 have licensee schedules which are yet to be determined. These items are, therefore, not included in this Order. The licensee considers some of the items addressed in this Order to be completed or to require no modifications.
These items are so noted in Attachments I and 2. The staff's evaluation of the licensee's delays for implementation of the remaining items is provided herein.
II.B.3 Post Accident Sampling By letter dated April 15, 1982, SCE informed the NRC of their intention to expand the post-accident sampling system to include on-line chloride and oxygen monitors. Subsequently, by letter dated December 3, 1982, SCE indicated that an undiluted sample facility would be provided rather than an on-line chloride monitor. SCE's letter dated February 16, 1983 stated that the Of analyzer and the-undiluted sample facility is targeted for comPletion during the Cycle 9 refueling outage (next refueling outage).
The NRC staff interprets this to mean that these items will be completed no later than the next refueling outage. A diluted grab sample capability currently exists.
The other requirements of item 1I.B.3 will be completed prior to startup from the current outage that began on February 27, 1982.
(7590-01
-4 II.E.1.2 Auxiliary Feedw-ater Initiation and, Flow Indication Three safety-grade relays and a safety-grade ammeter and transducer will be installed during the current outage which began on February.27, 1982.
This will complete the electrical upgrades necessary to comply with this item.
There is also mechanical equipment that needs to be upgraded to safety-grade to complete this item.
The delay in installing this equipment is due to the need on the part of the licensees to undertake programs to qualify this mechan ical equipment. These items will be installed no later than the next refueling outage. The control grade.equipment will be operational in the interim.
II.F.1(3-6) Accident Monitoring (4 items)
This requirement will be completed during the current outage that began on February 27, 1982.
11.0.1.3 Block Valve Test Program A PORY block valve adequacy report will be provided by June 1, 1983. The delay in the PORV report is due to a basic difference in the actuator used in the EPRI tests compared to the San Onofre Unit 1 actuators. Additional valve-specific analyses are needed to reach any'conclusions regarding the adequacy of the PORY.block valves installed at San Onofre Unit 1.
II.D.3.4 -Control Room Habitability
.The scheduled completion of the planned modifications to the control room wi.11 be established in conjunction with the schedule for completion of any modifi cations identified during the Systematic Evaluation Program Integrated Assessment. SCE also indicated that the schedule could be impacted by the requirements of TMI Action Plan Item I.D.1 - Control Room Design Reviews.
90-0 We find, based on the above evaluation; that:
(1) SCE has taken corrective actions regarding the delays and has made a responsible effort to implement the NUREG-0737 requirements noted; (2) there is good cause for the several delays (expansion of the post accident sampling system and qualification of mechanical equipment); and (3) as noted above, interim compensatory measures have been provided.
In view of the foregoing, I have determined that these modifications and actions are required in the interest of public health and safety and, therefore SCE's commitments should be confirmed by Order.
IV.
Accordingly, pursuant to Sections 103, 161i, and 161o of the Atomic Energy Act of 1954, as amended, and the Commission's regulations in 10 CFR Parts 2 and 50, IT IS HEREBY ORDERED EFFECTIVE IMMEDIATELY THAT the licensee shall:
Implement and maintain the specific items described in the Attachments to this Order in the manner described in SCE's submittals notet-in Section III herein no later than the dates in the Attachments.
V.
The licensees may request a hearing on this Order within 20 days of the date cf publication of this Order in the Federal Register.
A request for a.
hearing should be addressed to the Director, Office of Nuclear Reactor Reculation, U.S. Nuclear.Regulatory Commission, Washington, D.C.
20555.
(7590-01)
-6 A copy should also be sent to the Executive Legal Director at the same address. A REQUEST FOR HEARING SHALL NOT STAY THE IVMEDIATE EFFECTIVENESS OF THIS ORDER.
If a hearing is requested by the licensees, the Comission will issue an Order designating the time and place of any such hearing.
If a hearing is held concerning this Order, the issue to be considered at the hearing shall be whether, the licenseesishould comply with the require ments set forth in Section. IV of this Order.
This Order is effective upon issuance.
FOR THE NUCLEAR REGULATORY COMMISSION Darrell G. Eisenhut, Director I 1Division of Licensing Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland, this 14 day of March.
1983.
Attachments:
- 1. Licensee's Commitments on Applicable NUREG-0737 Requirements from Generic Letter 82-05
- 2. Licensee's.Connitments on Applicable NUREG-0737 Requirements from Generic Letter 82-10
SAN 01101 I1[ UNIT 1
-LLacjiiii64 I
LICENSEE 'S C)MITMITNTS ON APPLICABLE NUlREG-0737 ITEMS FOM GENERIC LETTER 82-05 NUREG-0737 Licensee's Completion Item Title Schedule Requ i rement Schedule (or status]
I.A.3.1 Simulator Exams 10/01/81 Include simulator exams in Complete licensing examinations 11.11.2 Plant Shielding 01/01/82 Modify facility to provide Complete access to vital areas under accident conditions 11.8.3 Post-Accident Sampling 01/01/82 Install upgrade post-accident No later than next refueling sampling capability outage.
11.U.4 Training for Mitigating 10/01/81 Complete training program Complete Core Damage Il.E.1.2 Aux. Feedwater Initiation 07/01/81 Modify instrumentation to No later than next refueling
& Flow Indication level of safety grade outage.
II.E.4.2 Containment Isolation 07/01/81 Part 5-lower containment Complete Dependability pressure setpoint to level compatible w/normal operation.
07/01/81 Part 7-isolate purge & vent Complete valves on radiation signal II.F.I Accident Monitoring 01/01/82 (1) Install noble gas effluent Complete moni tors.
U17U1782 (2) Provide capability Ior Lomple effluent monitoring of iodine 01101182 T1T TnaTflicontainment r
Ielin ll e
oua radiation-level monitors began on February 27, 1982..
01/01/82 (Fr (ovide con t inuou i
_6 titiu r
Tming
-IT currenf: oll.
The ti cation of containment pressure began on February 2/, 1982.
'0 1TO/82 (5)P(ovile conuLiois ili-Turiing TiecIrren-L. onTLa1 e 1
lifit cation of containment water began on February 21, 1982.
level.
I DTJ7J8A7
- (FFrovide continuous inTl-During the ciir1eiToTd 1TiT cation of hydrogen concentra-began on february 27,,1982.
[ion in containment.
Where completion date refers to a refuelinig outage (the estimated date when the outage begins), the item will be compileted prior to the restart of the facility
LICENSEE'S COMM ITME_'NTS ON APPLICABLE milREG-0737JL1 RMGNRCIUI~!
NUREG-0 737 cn e'sCpltIn itmTteSchedule Requi rement Schledule J(r SO-
- mj 1 Lem ine l.Al.3l imi Oertme10101/82 per Revise administrative proce-Compl~ete IA.3.1 LmtOetm Gen Lir 82-12 (lureS to limiit overtime in dtd. 6/15/82 accordance w/NRC Policy S tateeiitn issued by Generic Ltr. No. 8215 di 515/82 I.Al..2
- Mnimu Shft rewsupersededl by To be addressed in the Final To be addresscd ihi ia 1.A.1.3.2 MnmmSitCe uei sud Proposed Rule Rule on Licensed OperatorRueiised dtd. 8/30/.82 Staffing at NuclearPower Unts I.Cl
- Rvie mereny Speseed by Reference SECY 82-111, To be deteried' 1.C.1ReieEeec urs Procedures SECY 82-111 Requiremen'ts for Emergency
_-LRe-sponse Capability 11.0.1.2RV and SV Test Programs 7//82 Submit plant specific reports Complete on roIief valve and safety valve prbgram.
11.0.1.3Block Valve Test Program 070182 Submit report of results of To be submie by hine 1, test prEqyami______
II.K.3.30 & 31 SBLOCA Analysis 1 year Submit plant specific analyses To be determined fol lowinq after staff approval of wodu I approval of model Ill.A.1.2 Staffing Levels for Superseded by Reference SECY 82-111, To be Determined Emergency Situations 82-ill Requirements for Emergency Response Capability_______
III.A.1.2 Upgrade Emergency Support Facilities III.A.2.2 Meteorological Data H
It It 11.0.3.4 Control Room labitability To be dSeter-Modify facilityas identified Modifications 2o bQ scheduled in mined by by licensee study.
conjAnPction wiPL LCALe scNeliiEG 0Cor licensee completion of any modi ica Lions identified during the SEP Integrtmed Assessment.
oiercm leto date refers. to a refu ing -outage (the estimated date when the jotfagqe beiginls) i te itLem1-
-wi 11) be completedu prior to the restart of the afacility.
- PNot Part of Confirmatory Order.
dtd 830/2
~ afin a Nuler Pwe Uit
ENCLOSURE 3 Southern California Edison Company P. O.BOX800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORWeA 91770 ROBERT DIETCH TELEPHONE June 17, 1983 213 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 (withih 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.
Pr)R AD04-D o9_8_13A6
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 1 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 potential-ly 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_
En sure 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 BREA.KS 900 FIRE PROTECTION, SINGLE FAILURE CR ERIA FIRE PROTECTION, DEDICATED SIS, c
EBV VALVE ACTUATOR REPLACEMENTV SEISMIC UPGRADE, DRAWING VERIFICATION. ELECTRICAL EQUIPMENT QUALIFICATiON 600 TMI, FIRE PROTECTION SPHERE ENCLOSURE, z
SPA, TMI, STEAM
-500 x
GENERATOR SLEEVING z
-400 C Leg end0 2
FORECAST 1
3 COMMITTED 200 ORIGINAL PLANT D
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 O
60 u
o 4
40 u
20 1968 1969 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 1980 1981 1982 YEAR OF OPERATION
SAN ONOFRE UNIT 1 OPERATING HISTQRY Capacity Major Year Factor(%)
Modifications Investments (mifllion)
- 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 (611M), 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 EVALUATIO PROGRAM BACKFIT DEDICATED SAFETY INJECTION AND FEEDWATER SYSTEMS INSTRUMENTATION SYSTEM FOR DETECTION OF INADEQUATE CORE CCOLING 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 CILORIDE 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 SLOWDOWN 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 DETECTGRS OUTER CIRCLE TEMPERATURE AVERAGE CIRCUITS SECONDARY CHEMISTRY MONITORING GLAND SEAL EXHAUST SEISMIC MONITORING INSTRUMENTATION OPERATIONAL RADIATICrM.NTORING SYSTEM
SAN ONOFRE BACKFIT PLANNING PROCESS SELECTION OF CURRENT OUTAGE PROJECTS BACKFIT ORIGIN CONCEPTUAL PLAN 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 o OTHERS COST EST.
SAN ONOFRE BACKFIT PLANNING PROCESS IMPLEMENTATION OF CURRENT OUTAGE PROJECTS PRELIMINARY FINAL IMPLEMENTATION,
- SCOPE, COST 0 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 MONTR 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 01/01185 -
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 0
PARTIAL ENVIRONMENTAL QUALIFICATION 0
PARTIAL SYSTEMATIC EVALUATION PROGRAM 0
SYSTEM VOLTAGE DEGRADATION 4 KV UNDERVOLTAGE RELAYS 0
PRESSURIZER PORV BLOCK VALVES 0
DIESEL GENERATOR FANS 0
PARTICULATE EFFLUENT MONITORING SYSTEM PLATE-OUT CONCERN 0
ISOLATION VALVES FOR STEAM GENERATOR SAMPLE AND BLOWDON LINES 0
AUXILIARY FEEDWATER SYSTEM SAFETY GRADE UPGRADE 0
CONTAINMENT ISOLATION RELAYS 0
SIS ANNUNCIATOR WINDOWS
INITIAL SCHEDULE CYCLE X REFUELING OUTAGE MODIFICATIONS 0
PARTIAL FIRE PROTECTION APPENDIX R 0
PARTIAL SYSTEMATIC EVALJATION PROGRAM 0
COMPLETE ENVIRONMENTAL QJALIFICATION
-- 0 POST ACCIDENT SAMPLING SYSTEM OXYGEN AND CHLORIDE MONITORING 0
CONTROL ROOM HABITABILITY HVAC UPGRADE O
ECCS SINGLE FAILURE UPGRADE 0
DEDICATED SIS AND FEEDWATER SYSTEMS 0
SIS PUMP SUCTION NOZZLES
INITIAL.SCHEDULE CYCLE XI REFUELING OUTAGE MODIFICATIONS 0
COMPLETE FIRE PROTECTION APPENDIX R O
PARTIAL SYSTEMATIC EVALUATION PROGRAM 0
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 0
PARTIAL SYSTEMATIC EVALUATION PROGRAM 0
PARTIAL REQUIREMENTS FOR EMERGENCY RESPONSE CAPABILITY 0
PARTIAL INSTRUMENTATION SYSTEM FOR DETECTION OF INADEQUATE CORE COOLING O
RADIOLOGICAL EFFLUENT MONITORING SYSTEMS 0
HEAVY LOADS LIFT RIGS AND TURBINE DECK SPALLING PROTECTION 0
REPLACE SIS RECIRCULATION LINE O
CV 525 AND 527 VALVE SEATS
INITIAL SCHEDULE MODIFICATIONS IF NOT COMPLETED BY CYCLE XII REFUELING OUTAGE WOULD BE SCHEDULED AFTER THAT 0
COMPLETE SYSTEMATIC EVALUATION PROGRAM O
COMPLETE INSTRUMENTATION SYSTEM FOR DETECTION OF INADEQUATE CORE COOLING 0
COMPLETE REQUIREMENTS FOR EMERGENCY RESPONSE CAPABILITY 0
INLAND METEOROLOGICAL TOWER O
MODIFICATION TO THE 125-VDC SYSTEM O
CORRODED SAFETY RELEATED AND NON-SAFETY RELATED..PIPING 0
BATTERY NO.
1 0
SALTWATER COOLING VALVES POV 1-10 0
BORON ANALYZER 0
PROCESS PH METER 0
SLUDGE REMOVAL TRAP 0
INLET PRESSURE GAUGES ON RHR PUMPS 0
CONTAINMENT SUMP LEVEL CONTROLLER 0
STEAM PIPE EROSION 0
PERMANENT DOMESTIC WATER LINE TO UNIT 1 O
DEMINERALIZED WATER CROSS TIE O
TELECOMMUNICATIONS O
NORTH GUARD TOWER.VIDEO 0
STATION SERVICE TRANSFORMER O
SYSTEM DESCRIPTION 0
BREATHING AIR FOR SPHERE O
ELECTRICAL POWER BUSES O
INSTALL PERMANENT WALKWAY 0
CONTROL ROOM IMPROVEMENT 0
HALON AWS COM4JNICATION ROOM O
12 KV CONSTRUCTION POWER SYSTEM O
SEPARATE POWER SUPPLY TO LETDOWN ISOLATION VALVES 0
UPGRADE SAFETY RELATED AND NON-SAFETY RE.ATED POWER SUPPLY 0
SEQUENCER LOGIC BOARDS
- 0.
LOCAL ASHCROFT GAUGES O
SOLIDIFIED RESINS STORAGE BUILDING AND TRANSPORTATION EQUIPMENT 0
WASTE GAS DECAY TANK SYSTEM 0
COMPONENT COOLING WATER HEAT EXCHANGER SERVICEABILITY 0
5V-99 REPLACE ACTUATION TO RELIA8LE CHANNEL 0
TURBINE LAB DRAINS O
CONDENSATE STORAGE TANK FLOODING POTENTIAL 0
HEALTH PHYSICS BUILDING O
CHEMICAL AND VOLUME CONTROL SYSTEM VALVES MOV-LCV 11008, C AND D 0
CONTROL ROOM INSTRUMENT RACKS 1-5 0
FLUX MAPPING SYSTEM 0
NUISANCE ALARMS BATTERY CHARGER, HYDRAZINE LOW FLOW AND CONTAINMENT SUPPLY 0
SYNCHRO CHECK RELAY PROTECTION 0
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 0
SEISMIC MONITORING INSTRUMENTATION
- g g
SAFETY BASED INTEGRATED SCHEDULE INPUTS 0 SAFETY SIGNIFICANCE o CONSTRAINTS ON IMPLEMENTATION U 10% PLANT BETTERMENT 0 UUSTIFICATION FOR DEFERRAL 0 INTEGRATION
INTEGRATED SCHEDULE SAFETY SIGNIFICANCE PARAMETERS 0 SYSTEM IMPROVEMENT IMPACT ON RELIABILITY IMPACT ON FAILURE MODES O SYSTEM IMPORTANCE CRITICAL FUNCTIONS DOMINANT SEQUENCES.
METHODOLOGY 0 RELIABILITY ANALYSIS DATA FROM PRIOR PRA'S 0 DETERMINISTIC ANALYSIS O INSIGHTS FROM RELATED PRA'S
INTEGRATED SCHEDULE CONSTRAINTS ON IMPLEMENTATION 0
SCHEDULAR CONSTRAINTS 0
OUTAGE DURATION 0
MANPOWER CAPABILITY 0
CAPITAL EXPENDITURES 0
OTHERS
INTEGRATED SCHEDULE JUSTIFICATION FOR DEFERRAL O
SAFETY PLATEAU ACHIEVED 0
ALTERNATIVES AVAILABLE 0
COMPENSATING MEASURES 0
OVERALL SAFETY SIGNIFICANCE
INTEGRATED SCHEDULE UPDATING 0 INTEGRATION OF NEW REGULATORY REQUIREMENTS O FIRM SCHEDULE CHANGE IN OUTAGE DOES NOT AFFECT SCHEDULE O OPTIMIZATION PROCESS IMPROVED SAFETY PRIORITIZATION 0 NRC APPROVAL
I INTEGRATED SCHEDULE CONCLUSION 0 NECESSARY FOR STABILITY AND PREDICTABILIT O EMPHASIZES SAFETY SIGNIFICANCE 0 REQUIRES NRC ENDORSEMENT
I' 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