ML13310B108

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Forwards Summaries of All Regulatory Projects Included in Integrated Living Schedule & Edited Schedule of Backfits, in Response to NRC Request at 831122 Meeting
ML13310B108
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 12/06/1983
From: Baskin K
Southern California Edison Co
To: Harold Denton
Office of Nuclear Reactor Regulation
References
TAC-54376, TASK-***, TASK-RR NUDOCS 8312080104
Download: ML13310B108 (89)


Text

Southern California Edison Company E

P. O. BOX 800 2244 WALNUT GROVE AVENUE KENNETH P. BASKIN ROSEMEAD, CALIFORNIA 91770 VICE PRESIDENT 213-572-1401 December 6, 1983 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 Integrated Living Schedule San Onofre Nuclear Generating Station Unit 1

Reference:

Letter, Kenneth P. Baskin, SCE, to H. R. Denton, NRC, dated November 21, 1983 The referenced letter provided a schedule, by outage, for the total scope of projects identified for implementation at San Onofre Unit 1. This schedule and a summary of the input and process used to develop the schedule were presented to members of the Regulatory staff at a meeting on November 22, 1983. During that meeting additional information on the schedule was requested. Specifically it was requested that each regulatory project have the responsible NRC organization identified (NRR or Region V), that the percent of total weight determined for each project be provided, and that summary descriptions of the regulatory projects be provided to assist in identifying the scope and to provide the basis for the project ranking. The enclosures provide this additional information. is an edited schedule of backfits including more descriptive titles than in the previous submittal and an indication of the weight determined for each particular project. The schedule has also been edited to correct for a previous error in entering data into the computer for ranking. This error affected only one criterion for which the projects were evaluated but did cause some projects to have their priority changed. The enclosed revised schedule supplants the schedule provided with the referenced letter and distributed at the November 22, 1983 meeting. provides summaries of all the regulatory projects included in the schedule. These summaries include short descriptions of the modifications or issues requiring modifications, indicate the status of San Onofre Unit 1 with respect to meeting the intent of the issue for which the modifications are being implemented, describe the -degree to which the unit would be improved and the probability of any associated events. Together this information provides a summary of the inputs used to determine a project's relative priority.

8312080104 831206 PDR AD PDR D0C 050020 P~

Mr. H.

December 6, 1983 As indicated in previous correspondence, the information used in the ranking represents the current state of knowledge on each particular project.

Many of the projects (most notably SEP, Environmental Qualification and Supplement 1 to NUREG-0737) are the subject of continuing analysis and evaluation and can be expected to have their priority lowered or in some instances may be completely eliminated from further consideration. For purposes of evaluation for inclusion in the Integrated Living Schedule, these issues were ranked based on the assumption that modifications would be implemented in accordance with current deterministic regulatory criteria. It should also be noted that several of the.high priority projects address the seismic reevaluation program. Because the issues associated with these projects are currently undergoing extensive discussion between the NRC and Southern California Edison, the priorities and scopes of these projects are also subject to change.

If you require further information on this schedule or the projects, please contact me.

Yours truly, Enclosures

ENCLOSURE SONGS 1 RETURN TO SERVICE SCHEDULE Begin Outage Return to Service July 1, 1984 Cycle IX Oct. 1, 1985 Jan. 1, 1986 X

July 1, 1987 Oct. 1, 1987 XI April 1, 1989 July 1, 1989 XII Jan. 1, 1991 April 1, 1991 XIII Oct. 1 1992 Jan. 1, 1993 XIV July 1, 1994 Oct. 1, 1994 XV April 1, 1996 July 1, 1996 XVI Jan. 1, 1998 April 1, 1998 XVII Oct. 1, 1999 Jan. 1, 2000 XVIII July 1, 2001 Oct. 1, 2001 XIX April 1, 2003 July 1, 2003 XX Jan. 1, 2005 April 1, 2005 XXI Oct. 1, 2006 Jan. 1, 2007 XXII July 1, 2008 Oct. 1, 2008 XXIII April 1, 2010 July 1, 2010 GEH:0276F 12/02/83

Southern California Edison Company P. 0. BOX 800 2244 WALNUT GROVE AVENUE KENNETH P. BASKIN ROSEMEAD, CALIFORNIA 91770 TELEPHONE VICE PRESIDENT 213-572-1401 December 6, 1983 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 Integrated Li'ving Schedule San Onofre Nuclear Generating Station Unit 1

Reference:

Letter, Kenneth P. Baskin, SCE, to H. R. Denton, NRC, dated November 21, 1983 The referenced letter provided a schedule, by outage, for the total scope of projects identified for implementation at San Onofre Unit 1. This schedule and a summary of the input and process used to develop the schedule were presented to members of the Regulatory staff at a meeting on November 22, 1983. During that meeting additional information on the schedule was requested. Specifically it was requested that each regulatory project have the responsible NRC organization identified (NRR or Region V), that the percent of total weight determined for each project be provided, and that summary descriptions of the regulatory projects be provided to assist in identifying the scope and to provide the basis for the project ranking. The enclosures provide this additional information. is an edited schedule of backfits including more descriptive titles than in the previous submittal and an indication of the weight determined for each particular project. The schedule has also been edited to correct for a previous error in entering data into the computer for ranking. This error affected only one criterion for which the projects were evaluated but did cause some projects to have their priority changed. The enclosed revised schedule supplants the schedule provided with the referenced letter and distributed at the November 22, 1983 meeting. provides summaries of all the regulatory projects included in the schedule. These summaries include short descriptions of the modifications or issues requiring modifications, indicate the status of San Onofre Unit 1 with respect to meeting the intent of the issue for which the modifications are being implemented, describe the degree to which the unit would be improved and the probability of any associated events. Together this information provides a summary of the inputs used to determine a project's relative priority.

PDR ADOCII& 05000206 P

PDR

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F&SA

Mr. H.

December 6, 1983 As indicated in previous correspondence, the information used in the ranking represents the current state of knowledge on each particular project.

Many of the projects (most notably SEP, Environmental Qualification and Supplement 1 to NUREG-0737) are the subject of continuing analysis and evaluation and can be expected to have their priority lowered or in some instances may be completely eliminated from further consideration. For purposes of evaluation for inclusion in the Integrated Living Schedule, these issues were ranked based on the assumption that modifications would be implemented in accordance with current deterministic regulatory criteria. It should also be noted that several of the high priority projects address the seismic reevaluation program. Because the issues associated with these projects are currently undergoing extensive discussion between the NRC and Southern California Edison, the priorities and scopes of these projects are also subject to change.

If you require further information on this schedule or the projects, please contact me.

Yours truly, Enclosures

ENCLOSURE 1 SONGS 1 RETURN TO SERVICE SCHEDULE Begin Outage Return'to Service July 1, 1984 Cycle IX Oct. 1, 1985 Jan. 1, 1986 X

July 1, 1987 Oct. 1, 1987 XI April 1, 1989 July 1, 1989 XII Jan. 1, 1991 April 1, 1991 XIII Oct. 1 1992 Jan. 1, 1993 XIV July 1, 1994 Oct. 1, 1994 XV April 1, 1996 July 1, 1996 XVI Jan. 1, 1998 April 1, 1998 XVII Oct. 1, 1999 Jan. 1, 2000 XVIII July 1, 2001 Oct. 1, 2001 XIX April 1, 2003 July 1, 2003 XX Jan. 1, 2005 April 1, 2005 XXI Oct. 1, 2006 Jan. 1, 2007 XXII July 1, 2008 Oct. 1, 2008 XXIII April 1, 2010 July 1, 2010 GEH:0276F 12/02/83

SONGS 1 INTEGRATED LIVING SCHEDULE REGULATORY ITEMS BY REFUELING OUTAGE Originating Percent of Priority Project Organization Total Weight CYCLE 9 PROJECTS 1

SEP III-5.A Pipe Break Inside NRR 4.70%

Containment -

Leak Detection 2

Seismic Upgrade of Main Steam NRR 4.29%

and Feedwater Piping 3

Seismic Upgrade of Component NRR 3.63%

Cooling and SWC CYCLE 10 PROJECTS 3a Completion of Seismic Upgrade NRR 3.63%

of Component Cooling and SWC 4

SEP VII-3, XV-2, TMI, App. R NRR 2.54%

Third Train Auxiliary Feedwater 5

Seismic Evaluation of Electrical NRR 2.42%

Cabinets/Equipment 6

Seismic Upgrade of Residual NRR 2.23%

Heat Removal System 7

Efcomatic Actuator Replacement Region V 1.95%

8 SEP IX-3, Auxiliary Saltwater NRR 1.94%

Cooling Pump Upgrade (Partial) 9 Electrical Drawing Verification Region V 1.75%

Project CYCLE 11 PROJECTS 10 Wide Range Gas Monitor Plate-Out NRR 1.53%

Modification 11 SEP III-5.B, Pipe Break Outside NRR 1.53%

Containment-Leak Detection 12 Regulated Instrument Buses Region V 1.51%

13 SEP II-3.A & II-3.B, Hydrologic NRR 1.51%

Description and Flooding Potential High Groundwater

-2 Originating Percent of Priority Prolect Organization Total Weight 14 Seismic Upgrade of RWST NRR 1.51%

15 SEP IV-2, Reactivity Control NRR 1.50%

System Single Failure Protection 16 SEP IX-5, Ventilation System NRR 1.46%

Upgrades 17 SEP VII-l.A, Isolation of Reactor NRR 1.46%

Protection Systems 18 SEP V-11.B, RHR Interlock NRR 1.44%

Requirements 19 SEP V-11.A, Requirements for NRR 1.44%

Isolation of High and Low Pressure Systems CYCLE 12 PROJECTS 19a Completion of SEP V-II.A, NRR 1.44%

Requirements for Isolation of High and Low Pressure System 20 Safety Injection System NRR 1.44%

Modifications 21 SEP III-5.A, Pipe Break Inside NRR 1.40%

Containment - Pipe Whip Restraints, Barriers, etc.

CYCLE 13 PROJECTS 21a Completion of SEP III-5.A, Pipe NRR 1.40%

Break Inside Containment - Pipe Whip Restraints, Barriers, etc.

22 Safety Grade Upgrade of AFWS NRR 1.38%

Equipment 23 Health Physics Facility Upgrade, Region V 1.36%

Including Facilities for Men and Women 24 Seismic Evaluation of Vent NRR 1.35%

Stack 25 SEP III-4.A Upgrade Plant NRR 1.34%

Structures and Equipment for Tornado Missiles

-3 Originating Percent of Priority Prolect Organization Total Weight CYCLE 14 PROJECTS 25a Completion of SEP III-4.A NRR 1.34%

Upgrade Plant Structures and Equipment for Tornado Missiles 26 Seismic Upgrade of Accident NRR 1.34%

Mitigation Systems CYCLE 15 PROJECTS 26a Completion of Seismic Upgrade NRR 1.34%

of Accident Mitigation Systems 27 SEP II.1.C (Also TMI and Seismic NRR 1.34%

Upgrade) Control Room HVAC Replacement/Upgrade 28 SEP 111-2 Upgrade Plant Structures NRR 1.33%

for Wind and Tornado Loads 29 SEP VI-7.C.2, Failure Mode NRR 1.24%

Analysis ECCS CYCLE 16 PROJECTS 29a Completion of SEP VI-7.C.2, NRR 1.24%

Failure Mode Analysis ECCS 30 Reactor Coolant Pump Lift Rigs NRR 1.20%

31 SEP VI-7.B, ESF Switchover from NRR 1.19%

Injection to Recirculation 32 Fire Protection Appendix R NRR 1.16%

Safe Shutdown - Phase 1 CYCLE 17 PROJECTS 32a Fire Protection Appendix R NRR 1.16%

Safe Shutdown -

Phase 2 CYCLE 18 PROJECTS 33 SEP VI-7.C.2, Redundant Valve NRR 1.16%

in Recirculation Path to Loop B Hot Leg (Partial Single Failure Analysis) 34 Regulatory Guide 1.97 NRR 1.16%

-4 Originating Percent of Priority Project Organization Total Weight 35 Replace GE Cable to RHR Pumps NRR 1.09%

36 Steel Decking Under Turbine Deck NRR 1.09%

North Extension 37 SEP VI-7.C.2, Upgrade Redundant NRR 1.09%

N2 Supply to FCV 1115 DEF (Partial Single Failure) 38 Upgrade Temporary Volume Control Region V 1.09%

Tank Level Instrumentation 39 Seismic Upgrade of Electrical NRR 1.08%

Raceways CYCLE 19 PROJECTS 39a Completion of Seismic Upgrade NRR 1.08%

of Electrical Raceways 40 SEP III-5.B, Pipe Break Outside NRR 1.08%

Containment -

Pipe Whip Restraints, Barriers, etc.

41 Control Room Design Review -

NRR 1.07%

Phase 1 CYCLE 20 PROJECTS 41a Control Room Design Review -

NRR 1.07%

Phase 2 42 SEP VIII-3.B, DC Power System NRR 1.07%

Bus Voltage Monitoring and Annunciation 43 SEP III-7.B Design Codes, Criteria NRR 1.07%

and Load Combinations Containment LOCA & Seismic Analysis 44 SEP VIII-4, Electrical Penetration NRR 1.06%

of Containment 45 Environmental Qualification -

NRR 1.05%

Phase 1 CYCLE 21 PROJECTS 45a Environmental Qualification -

NRR 1.05%

Phase 2

-5 Originating Percent of Priority Prolect Organization Total Weight 46 Valve Seat Upgrade/Replacement NRR 1.05%

CV 525 & 527 47 Replacement of SV99 Actuation Region V 1.04%

Circuit 48 SEP VI-4, Containment Isolation NRR 1.03%

Electrical (Partial)

Provide CIAS for Inside RCSS Valves and Eliminate Override on Outside Valves 49 SEP VI-4, Containment Isolation NRR 1.03%

Systems 50 Automatic Trip of Reactor Coolant NRR 1.03%

Pumps CYCLE 22 PROJECTS 51 CVCS Valves MOV-LCV-1100B, C, D Region V 1.02%

52 12 kV Construction Power System NRR 1.02%

Improvements 53 SEP VI-4, Containment Isolation NRR 1.00%

Electrical (Partial)

Diesel Generator Radiator Fans Loading 54 SEP VIII-1.A, Potential Equipment NRR 1.00%

Failures Associated with Degraded Grid Voltage 55 Waste Gas Decay Tank Monitoring Region V 0.99%

Instrumentation 56 NIS Rockbestos Cable Replacement NRR 0.99%

57 Condensate Storage Tank Flooding NRR 0.99%

Potential 58 SEP IX-3, Station Service and NRR 0.99%

Cooling Water Systems (Partial) 59 SEP VI-4 Containment Isolation NRR 0.99%

Electrical (Partial)

Re-Letter "Block SIS" Annunciator Window

.4 S

-6 Originating Percent of Priority Project Organization Total Weight 60 Seismic Upgrade of South Turbine NRR 0.98%

Extension 61 SEP III-1, Classification of NRR 0.98%

Structures, Systems, and Components 62 Safety Parameter Display System NRR 0.98%

63 Inadequate Core Cooling -

Phase 1 NRR 0.97%

CYCLE 23 PROJECTS 63a Inadequate Core Cooling - Phase 2 NRR 0.97%

64 SEP XV-1, Increase in Feedwater NRR 0.97%

Flow 65 SEP VII-3, Systems Required for NRR 0.97%

Safe Shutdown (Redundant Component Cooling Level Instrumentation) 66 Radiological Effluent Technical NRR 0.96%

Specification Modifications 67 Post Accident Sampling 02 and NRR 0.96%

C1 Monitoring 68 Improvements to Operational Region V 0.95%

Radiation Monitoring System 69 SEP II-3.A, II-3.B and III-3.A, NRR 0.94%

Ventilation Building and Fuel Storage Building Rooftop Drainage 70 Solidified Resin Storage Facility Region V 0.93%

71 SEP V-10.A, Residual Heat Removal NRR 0.92%

Heat Exchanger Tube Failures 72 SEP V-5, Reactor Coolant Pressure NRR 0.91%

Boundary Leakage Detection 73 SEP III-8.A, Loose Parts NRR 0.90%

Monitoring System GEH:0314F

SONGS 1 INTEGRATED LIVING SCHEDULE BETTERMENT ITEMS BY CYCLE Percent of Priority Prolect Total Weight CYCLE 9 PROJECTS 1

Battery No. 1 10.36%

2 Phase II Waste Gas Decay Tanks Replacement/

5.57%

Upgrade 3

Upgrade Balance of Safety Related Snubbers -

4.93%

Phase 1 CYCLE 10 PROJECTS 3a Upgrade Balance of Safety Related Snubbers -

4.93%

Phase 2 CYCLE 11 PROJECTS 3b Upgrade Balance of Safety Related Snubbers -

4.93%

Phase 3 4

SR & NSR Piping Corrosion 4.86%

CYCLE 12 PROJECTS 5

Charging Test Pump Discharge 3.81%

Relief Valve RV-259 6

CCW Hx Serviceability 3.24%

7 Containment Sump Level Controller 2.82%

Deadband and Float Sludge 8

RCS Pressure Indication: Separate 2.49%

Power Supplies to PI-434, 425 9

Separate Power Supply for Letdown Isolation 2.24%

Valves CV 202, 203, 204 10 Boron Analyzer 2.06%

12 FW Flow Control System Analysis 2.04%

13 Recirculation System for Radwaste Monitor 1.90%

Tanks D-21A and D-21B 14 Secondary Chemistry Monitoring 1.84%

-2 Percent of Priority Prolect Total Weight 15 Replace SIS Recirculation Line 1.65%

280' of Sch. 10 Pipe w/Sch. 40 Pipe CYCLE 13 PROJECTS 11 Electrical Power Buses Load Study -

Phase 1 2.04%

CYCLE 14 PROJECTS 1la Electrical Power Buses Load Study - Phase 2 2.04%

CYCLE 15 PROJECTS 16 Control Room Improvement 1.58%

17 Inlet Pressure Gauges on RHR Pumps 1.50%

18 S.I. Recirc. to Hotwell Line (add. valves) 1.45%

19

System Description

1.44%

20 HP Oil Line, Turbine LO Reservoir 1.41%

21 Process pH Meter 1.31%

22 Breathing Air for Sphere 1.31%

23 Gland Seal Exhaust (Replacing Hood and Ducting) 1.25%

25 RWST: Weep Hole Leakage 1.20%

Absence of Cathodic Protection (Tank Bottom)

CYCLE 16 PROJECTS 24 Relief Valve Test Facility 1.21%

26 Install Permanent Walkway 1.17%

27 Flux Mapping System 1.16%

28 Liquid Nitrogen Storage Tank Foundation 1.16%

CYCLE 17 PROJECTS 29 Demineralized Water Cross Tie 1.16%

CYCLE 18 PROJECTS 30 Synchro Check Relay Protection 1.04%

-3 Percent of Priority Prolect Total Weight 31 Containment Air Lock Operating 1.05%

Mechanism 32 Seismic Battery 1 Restraint Improvement 1.01%

33 Steam Generator Manway Tensioner 1.00%

CYCLE 19 PROJECTS 34 Subcooled Margin Monitor 1.00%

35 Sequencer Logic Boards Redesign

.99%

36 Alternate Power Source AWS Bldg.

.99%

37 Nuisance Alarms: Hydrazine

.99%

Low Flow and Containment Supply 38 Temperature Average Circuit Upgrades

.99%

39 Upgrade Plant Air Systems

.99%

CYCLE 20 PROJECTS 40 Nos. 1 and 2 Sequencer Test Switches

.98%

41 Main Feedwater Line Miniflow Line CV36 and 37

.97%

Replacement for Pipe Wall Erosion 42 Health Physics Facilities Site Improvements

.97%

Phase 1 CYCLE 21 PROJECTS 42a Health Physics Facilities Site Improvements Phase 2 43 Source Range Excore Nuclear Instrumentation

.96%

Channels 45 Diesel Generator Cooling Jacket Water

.94%

Sample Point Upgrade CYCLE 22 PROJECTS 44 Control Room Instrument Racks 1-5

.96%

46 Security Improvements: Modify Alarm Points

.93%

47 Synchro Check Relay Protection Upgrade for

.91%

Main Generator

-4 Percent of Priority Prolect Total Weight 48 Valves POV 1-10 Star Wheel Improvements

.90%

49 Update Circuit and Raceway Program

.89%

50 Upgrade Power Supply to Decontamination

.89%

System Electro Polisher 51 Gate Valves MOV 1201, 1202, 1204 & 11OOE:

.89%.

Premature Indication of Closed Position 52 Sludge Removal Trap

.89%

53 Replace Local Ashcroft Gauges

.88%

54 Complete Design Criteria Documentation

.88%

55 Diesel Generator Building Water Drains in

.87%

Ventilation Deflectors 56 Mods. to Liquid Waste Hold Up Tanks

.87%

(Route Anti-siphon Vents to Floor Drains) 57 Station Service Transformer Cooling Fans

.87%

Circuit Redesign CYCLE 23 PROJECTS 58 Permanent Domestic Water Line to Unit 1

.86%

59 Eliminate Automatic Actuation of Emergency

.85%

Warning Sirens GEH:0313F

TNCLOSURE 2 PRIORITY 1 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP III-5.A Pipe Break Inside Containment - Leak detection INTENT:

Provide leak detection for major lines inside containment to support leak-before-break.

STATUS WITH RESPECT TO CURRENT PLANT:

Plant was not.specifically designed for protection from high energy line breaks.

There currently exists the capability to detect leaks, but improvements may be required in sensitivity to support analysis.

Alternate means of shutdown may be available.

DEGREE OF IMPROVEMENT:

Substantial improvement in capability to predict potential high energy line breaks at particular locations.

PROBABILITY OF EVENT:

High Energy Line Breaks are low probability events in SR piping.

PRIORITY 2 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Seismic Upgrade of Main Steam and Feedwater Piping INTENT:

Complete seismic upgrade of steam and feedwater piping to ensure capability to withstand 0.67g Housner earthquake.

STATUS WITH RESPECT TO CURRENT PLANT:

Original design is to 0.5g Housner.

DEGREE OF IMPROVEMENT:

Substantial improvement for difference in 0.5g to 0.67g Housner earthquake due to relatively high consequences of steam or feedwater line break.

PROBABILITY OF EVENT:

Difference between probability of 0.5g and 0.67g earthquake is very low.

PRIORITY 3 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE: Seismic Upgrade of Component Cooling and SWC INTENT:

Complete seismic upgrade of component cooling water and saltwater cooling system piping to ensure capability to withstand 0.67g Housner earthquake.

STATUS WITH RESPECT TO CURRENT PLANT:

Original design is to 0.5g Housner. Saltwater lines are cast iron.

DEGREE OF IMPROVEMENT:

Moderate since alternate means of maintaining safe shutdown are available.

PROBABILITY OF EVENT:

Difference between probability of 0.5g and 0.67g earthquake is very low.

PRIORITY 4 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP VII-3, XV-2, TMI, App. R, Third Train Auxiliary Feedwater INTENT:

Add third train of auxiliary feedwater to mitigate steamline breaks with single failure of motor driven train, also assists in normal shutdown, could help partially meet Appendix R requirements.

STATUS WITH RESPECT TO CURRENT PLANT:

Two trains currently exist. Auxiliary feedwater system is not protected against steamline break with coincident single failure. Existing trains currently within five feet of each other.

For some breaks the feedwater pumps can be used for continued feedwater addition.

DEGREE OF IMPROVEMENT:

Strong improvement in auxiliary feedwater system due to unavailability in event of single failure.

PROBABILITY OF EVENT:

Auxiliary feedwater has been shown to be an important safety system.

0 0

PRIORITY 5 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Seismic Evaluation of Electrical Cabinets/Equipment INTENT:

Evaluate and upgrade as required electrical cabinets and attachment of electrical equipment internal to cabinets to ensure capability to withstand 0.67g Housner earthquake.

STATUS WITH RESPECT TO CURRENT PLANT:

All cabinet anchorages have been upgraded to 0.67g.

DEGREE OF IMPROVEMENT:

Moderate since experience shows that well anchored electrical equipment tend to remain functional after earthquakes; however, cabinets affect all safety related electrical equipment.

PROBABILITY OF EVENT:

Probability of 0.67g earthquake is very low.

PRIORITY 6 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Seismic Upgrade of Residual Heat Removal System INTENT:

Complete upgrade of RHR system to ensure capability to withstand 0.67g Housner earthquake.

STATUS WITH RESPECT TO CURRENT PLANT:

If RHR system is unavailable can maintain safe shutdown using either auxiliary feedwater or primary feed and bleed.

DEGREE OF IMPROVEMENT:

Moderate since alternate means of maintaining site shutdown are available.

PROBABILITY OF EVENT:

Probability of 0.67g earthquake is very low.

PRIORITY 7 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Efcomatic Actuator Replacement INTENT:

Replace 10 actuator assemblies located in safety-related systems.

Operation of the actuators has been demonstrated unreliable.

STATUS WITH RESPECT TO CURRENT PLANT:

Monthly operation required for existing actuators. If actuators fail monthly test during operation this would result in plant shutdown.

DEGREE OF IMPROVEMENT:

Strong improvement due to reliability of new actuators and removal of monthly testing requirement.

PROBABILITY OF EVENT:

Failures of the actuators have occurred during the monthly test.

PRIORITY 8 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP IX-3, Auxiliary Saltwater Cooling Pump Upgrade (Partial)

INTENT:

Upgrade the auxiliary saltwater cooling pump to safety-related (Safety Class 3, Seismic Category 1) commensurate with its accident mitigation functions. These accidents are loss of the normal saltwater cooling pumps due to failure of the tsunami gates in the closed position or due to flooding from a circulating water pump bellows failure.

STATUS WITH RESPECT TO CURRENT PLANT:

Two saltwater cooling trains currently exist. Protection from tsunami gate failing closed and circulating water pump bellows failure is provided by non-safety related means (fire protection water and auxiliary saltwater cooling pump).

Sufficient water may be available through intake structure even with tsunami gates in closed position.

DEGREE OF IMPROVEMENT:

Moderate improvement in the availability of saltwater cooling, through alternate supplies are available for accident scenarios.

PROBABILITY OF EVENT:

Most severe event is earthquake induced.

Probability of events without an earthquake are low.

PRIORITY 9 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Electrical Drawing Verification Project INTENT:

Upgrade drawings to reflect as-built condition of SONGS 1. This is an extension of the P&ID Verification project.

STATUS WITH RESPECT TO CURRENT PLANT:

Drawings are not up-to-date and can require substantial field work to verify.

DEGREE OF IMPROVEMENT:

Drawings exist but are difficult to trace. Result of project would be accurate, up-to-date drawings. Startup verifies system functionability.

PROBABILITY OF EVENT:

There are no particular events involved with this project, but the drawings are important in maintaining a low error rate in working with existing equipment.

  • 1,4 PRIORITY 10 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE: Wide Range Gas Monitor Plate-Out Modification INTENT:

To modify the post-accident wide range plant stack gas monitoring system to reduce the plate-out in the low-flow, high-radiation sample line. It will provide additional confidence in the post-accident dose assessment.

STATUS WITH RESPECT TO CURRENT PLANT:

The current system configuration allows the lower ranges to be monitored, but the higher ranges cannot be directly measured at the plant stack.

Alternate means either offsite or at the site perimeter must be taken to affect the same capability lost due to plate-out.

DEGREE OF IMPROVEMENT:

Strong, due to the direct measurement capability that is currently unavailable. Must be tempered by considering that a factor of 2 is used for conservatism in offsite dose assessment.

PROBABILITY OF EVENT:

Offsite emergency team uses monitor readings to assist in determining response to the accident.

PRIORITY 11 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP III-5.B, Pipe Break Outside Containment-Leak Detection INTENT:

Provide analysis and methods to support leak-before-break on medium energy lines outside containment.

STATUS WITH RESPECT TO CURRENT PLANT:

There is a program established to monitor high energy lines from earlier analysis, but nothing in-place for moderate energy lines.

Operator currently performs plant walk-throughs and would notice leaking lines.

DEGREE OF IMPROVEMENT:

Moderate. Any major leaks would probably currently be detected but a formal program is not established to evaluate specific break locations and analysis to demonstrate acceptability has not been performed.

PROBABILITY OF EVENT:

Break or ruptures are unlikely but have occurred in certain NSR pipes at other plants.

PRIORITY 12 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Regulated Instrument Buses INTENT:

Provide indication in control room of regulated instrument bus status.

Failure of one of these buses previously caused erratic feedwater flow leading to a safety injection signal.

STATUS WITH RESPECT TO CURRENT PLANT:

There is no indication of bus status in the control room. Operator would have to be sent to make a local determination of bus failure.

DEGREE OF IMPROVEMENT:

Moderate. Operator will not have to spend unnecessary time trying to determine whether troubles are being caused by loss of a particular bus.

PROBABILITY OF EVENT:

'Failure of one bus has previously caused erratic feedwater flow which eventually resulted in a safety injection signal being generated.

PRIORITY 13 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP II-3.A & II-3.B, Hydrologic Description and Flooding Potential, High Groundwater INTENT:

Assure plant is protected from high groundwater levels.

STATUS WITH RESPECT TO CURRENT PLANT:

The current plant design basis is the site average groundwater level.

Experience has demonstrated plant ability to date to withstand high groundwater.

DEGREE OF IMPROVEMENT:

Weak due to demonstrated ability to withstand high groundwater conditions (groundwater levels in excess of the average). High groundwater would potentially cause common mode failure problems.

PROBABILITY OF EVENT:

Probability of high groundwater exceeding the plant hydrostatic capability is low.

PRIORITY 14 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Seismic Upgrade of RWST INTENT:

Upgrade RWST to ensure capability to withstand 0.67g Housner earthquake.

STATUS WITH RESPECT TO CURRENT PLANT:

Existing RWST designed for 0.5g Housner. Preliminary analysis indicates that RWST may be able to withstand 0.67g.

DEGREE OF IMPROVEMENT:

Small since backup source of water will be available and existing RWST has substantial seismic capability.

PROBABILITY OF EVENT:

Probability of 0.67g earthquake is very low.

PRIORITY 15 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE: *SEP IV-2, Reactivity Control System Single Failure Protection INTENT:

Install protection of the reactivity control systems (i.e., control rods and shutdown rods) to ensure that single failures do not cause reactivity changes that will affect fuel integrity.

STATUS WITH RESPECT TO CURRENT PLANT:

The single failures analyzed show that certain rod.movements may result in reactivity changes that need to be analyzed for their affects on fuel integrity.

DEGREE OF IMPROVEMENT:

The single failures can happen, but are of low probability. The plant is designed to mitigate the consequences of a single failure, and further analysis may show that fuel design limits are not exceeded.

PROBABILITY OF EVENT:

Low

PRIORITY 16 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP IX-5, Ventilation System Upgrades INTENT:

Install single failure proof ventilation systems in the 480V room, 4 kV room, battery room and the auxiliary building.

STATUS WITH RESPECT TO CURRENT PLANT:

Ventilation has been installed in the 480 V and 4 kV rooms though their adequacy in post accident conditions has not been conclusively demonstrated but is expected to be adequate due to reduced electrical loads in such conditions. The battery room has a commercial grade HVAC DEGREE OF IMPROVEMENT:

Temperature has not historically been a problem in these rooms, but recent changes in the 480V and 4 kV rooms may change this.

The battery room HVAC is of commercial grade.

PROBABILITY OF EVENT:

Low, extreme external temperatures rarely occur at the San Onofre site.

Newly installed equipment should be able to be demonstrated acceptable.

Inverter room has historically not been a problem.

PRIORITY 17 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP VII-1.A, Isolation of Reactor Protection Systems INTENT:

Install proper isolation of these systems from non-necessary lower class systems to provide assurance that the RPS will perform its function.

STATUS WITH RESPECT TO CURRENT PLANT:

The analyses show that certain systems are not isolated per current criteria.

DEGREE OF IMPROVEMENT:

Due to the low probability contribution of this non-isolation to total RPS failure rate, the improvement is minor.

PROBABILITY OF EVENT:

Low

PRIORITY 18 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP V-11.B, RHR Interlock Requirements INTENT:

Install independent interlocks on RHR isolation valves. Provide a Technical Specification on OMS for RHR protection.

STATUS WITH RESPECT TO CURRENT PLANT:

Two isolation valves are currently under interlock. The remaining valves are administratively controlled. Technical Specification for OMS under NRC review.

DEGREE OF IMPROVEMENT:

Minimal improvement due to equipment failure and operator error required to cause an RHR overpressurization.

PROBABILITY OF EVENT:

Low as demonstrated by NRC PRA.

PRIORITY 19 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP V-11.A, Requirements for Isolation of High and Low Pressure Systems INTENT:

Provide interlocks on isolation valves in SIS, Recirculation and CVCS systems to prevent overpressurization of low pressure systems.

STATUS WITH RESPECT TO CURRENT PLANT:

Check valves in series with isolation valves are tested as required by procedure.

DEGREE OF IMPROVEMENT:

Minimum improvement since there are procedural checklists ensuring isolation valves are closed and check valves are tested.

PROBABILITY OF EVENT:

Low due to the frequency of testing of check valves and isolation valves.

PRIORITY 20 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Safety Injection System Modifications INTENT:

Modify SIS/Feedwater system such that they no longer share common equipment such as feedwater pumps. Modification would install new feedwater pumps and piping. This would eliminate Feedwater pump sequencing which previously led to SI valve failures.

STATUS WITH RESPECT TO CURRENT PLANT:

Modifications have been installed which eliminate previous problem.

There is in place a continuing surveillance program to demonstrate system reliability.

DEGREE OF IMPROVEMENT:

Small improvement in reliability due to complete system separation.

PROBABILITY OF EVENT:

Low

PRIORITY 21 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP III-5.A, Pipe Break Inside Containment -

Pipe Whip Restraints, Barriers, etc.

INTENT:

Provide protection against the effects of high energy line breaks inside the containment. Modifications include barriers, restraints, relocation and/or target qualification.

STATUS WITH RESPECT TO CURRENT PLANT:

Plant was not specifically designed for protection from high energy line breaks.

DEGREE OF IMPROVEMENT:

Substantial improvement in capability to safety shutdown in the event of a particular high energy line break. Alternate modes of shutdown may be available (e.g., feed and bleed).

PROBABILITY OF EVENT:

High Energy Line Breaks are low probability events in SR piping. Breaks in non-safety system have occurred at other plants.

PRIORITY 22 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Safety Grade Upgrade of AFWS Equipment INTENT:

Install safety-grade positioner and air set (including nitrogen backup) for AFWS. Will assure control of AFWS flow control valves to any position rather than only assuring fail open. Also, new safety relief valve for steam supply to steam driven pump, to be installed.

STATUS WITH RESPECT TO CURRENT PLANT:

Will improve control of AFWS from-control room. Current system has capability to perform post-accident.

DEGREE OF IMPROVEMENT:

System as designed is adequate to perform safety function. Significant improvement will occur with respect to operability.

PROBABILITY OF EVENT:

Medium - AFWS used following many events.

PRIORITY 23 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Health Physics Facility Upgrade, Including Facilities for Men and Women INTENT:

Provide a facility to assist in better controlling access and egress from radiological areas.

STATUS WITH RESPECT TO CURRENT PLANT:

System is frequently very crowded -and can lead to a lack of control of health physics monitoring. There are not now separate facilities for men and women.

DEGREE OF IMPROVEMENT:

Substantial improvement in health physics control for all plant conditions including operation and outage.

PROBABILITY OF EVENT:

No accident events are associated wth the health physics facility, but it is used to monitor radiaiton exposure.

9e e

PRIORITY 24 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Seismic Evaluation of Vent Stack INTENT:

To evaluate and upgrade as required the vent stack to ensure that it will not affect safety related systems and equipment following a 0.67g Housner earthquake.

STATUS WITH RESPECT TO CURRENT PLANT:

Vent stack is sheet metal and has very large foundation but no support at higher elevations.

DEGREE OF IMPROVEMENT:

Small since even if the vent stack were to fail in an earthquake, there is significant probability that it will not impact safety related equipment. Catastrophic failure is not likely.

PROBABILITY OF EVENT:

Probability of 0.67g earthquake is very low.

PRIORITY 25 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP III-4.A Upgrade Plant Structures and Equipment for Tornado Missiles INTENT:

Upgrade plant structures to ensure that the tornado missiles generated by the design basis tornado do not prevent safe shutdown.

STATUS WITH RESPECT TO CURRENT PLANT:

The current plant is not specifically designed for the tornado missile hazard with the exception of the sphere enclosure building and the diesel generator building. Some systems are protected but complete paths have not been demonstrated.

DEGREE OF IMPROVEMENT:

Substantial, due to the lack of plant wide design in this area.

PROBABILITY OF EVENT:

Tornado event is low.

PRIORITY 26 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Seismic Upgrade of Accident Mitigation Systems INTENT:

Complete upgrade of accident mitigation systems to ensure capability to withstand 0.67g Housner earthquake.

STATUS WITH RESPECT TO CURRENT PLANT:

.. Original design is 0.5g Housner. Containment spray ring upgraded to 0.67g Housner.

DEGREE OF IMPROVEMENT:

Small since reactor coolant system upgraded to 0.67g to ensure an accident will not occur due to an earthquake.

PROBABILITY OF EVENT:

Probability of 0.67 earthquake is very low.

PRIORITY 27 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP II.l.C (Also TMI and Seismic Upgrade) Control Room HVAC Replacement/Upgrade INTENT:

To upgrade the control room HVAC to be single failure proof and to protect control room personnel from offsite toxic gas exposure and post-accident conditions.

STATUS WITH RESPECT TO CURRENT PLANT:

Current system is isolatable but not single failure proof and does not have toxic gas isolation. Also, it is not upgraded to 0.67g Housner earthquake.

DEGREE OF IMPROVEMENT:

Since system is currently isolatable upgrade will not significantly improve operation.

PROBABILITY OF EVENT:

Offsite hazard is minimal.

Large radiation releases are low probability events. A 0.67g Housner earthquake is a low probability event.

PRIORITY 28 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP 111-2 Upgrade Plant Structures for Wind and Tornado Loads INTENT:

Upgrade plant structures to withstand design basis tornado loads.

STATUS WITH RESPECT TO CURRENT PLANT:

The current plant is not designed for design basis tornado with the exception of the sphere enclosure building and the diesel generator building. Some systems have as-built capability to withstand loads but shutdown paths have not been identified.

DEGREE OF IMPROVEMENT:

Substantial for exposed systems, less for those already with some degree of protection.

PROBABILITY OF EVENT:

Tornado event is low probability.

PRIORITY 29 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP VI-7.C.2, Failure Mode Analysis ECCS INTENT:

Install recommendations made in single failure reports dated December 20, 1976 and December 21, 1977.

STATUS WITH RESPECT TO CURRENT PLANT:

Necessary-modifications have been implemented and interim modifications installed for others. No actions has been taken on items in December 21, 1977 report.

DEGREE OF IMPROVEMENT:

Some improvement in operation and maintenance for interim modifications.

Remaining items have not been concluded to be a significant safety hazard.

PROBABILITY OF EVENT:

Very low since interim modifications have been implemented.

0-PRIORITY 30 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Reactor Coolant Pump Lift'Rigs INTENT:

To reduce risk of a drop of the reactor coolant pump motors on to the reactor coolant pumps during maintenance.

STATUS WITH RESPECT TO CURRENT PLANT:

Current lift rigs have not been analyzed to establish current safety level.

The replacement cost of the rigs is comparable to performing this analysis. Current rigs have been used for years.

DEGREE OF IMPROVEMENT:

Unknown.

PROBABILITY OF EVENT:

Low based upon past plant and industry history.

PRIORITY 31 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP VI-7.B, ESF Switchover from Injection to Recirculation INTENT:

Provide redundant level instrumentation on the RWST and automate the stopping of injection and initiation of recirculation.

STATUS WITH RESPECT TO CURRENT PLANT:

All actions are manual.

Time available to perform actions is in question since it is less than the NRC desired time. A single instrument and alarm is provided on the RWST.

DEGREE OF IMPROVEMENT:

Automated recirculation would improve operator actions following a LOCA.

PROBABILITY OF EVENT:

It has been demonstrated that large break LOCA 'is a low probability event. Much additional time would be available for small break LOCA's.

PRIORITY 32 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Fire Protection Appendix R Safe Shutdown INTENT:

Provide modifications to meet criteria set forth in Appendix R to 10 CFR

50.

STATUS WITH RESPECT TO CURRENT PLANT:

Extensive fire suppression systems are installed. Alternate shutdown capability is installed and available. Casualty procedures have been established.

DEGREE OF IMPROVEMENT:

Weak due to established programs.

PROBABILITY OF EVENT:

Fires have occurred but improved awareness and protection lowers probability.

PRIORITY 33 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP VI-7.C.2, Redundant Valve in Recirculation Path to Loop B Hot Leg (Partial Single Failure Analysis)

INTENT:

Increase the reliability of Hot Leg Recirculation by making it single failure proof.

STATUS WITH RESPECT TO CURRENT PLANT:

Alternate Hot Leg Recirculation path has been implemented as an interim modification.

DEGREE OF IMPROVEMENT:

Minimal since alternate path has been developed.

PROBABILITY OF EVENT:

Low since alternate path will be available.

0 9

PRIORITY 34 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Regulatory Guide 1.97 INTENT:

Upgrade plant instrumentation and systems as necessary to meet the criteria of Regulatory Guide 1.97.

STATUS WITH RESPECT TO CURRENT PLANT:

The current plant in many cases does not meet the redundancy and environmental qualification requirements of Regulatory Guide 1.97.

DEGREE OF IMPROVEMENT:

Minor, due to the fact that there is currently adequate instrumentation to support the emergency procedures, but may be lacking redundancy in all cases.

EQ is being addressed independently PROBABILITY OF EVENT:

This instrumentation is used post accident for many events.

PRIORITY 35 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Replace GE Cable to RHR Pumps INTENT:

Replace cable which has been identified to not be qualified if it contains manufacturer splices.

STATUS WITH RESPECT TO CURRENT PLANT:

Manufacturer splices have not been identified in installed cable.

Failure of this cable would result in loss of RHR pump.

DEGREE OF IMPROVEMENT:

Improvement would ensure qualified cable is installed.

PROBABILITY OF EVENT:

Low probability since splices have not been identified and two RHR pumps are available.

PRIORITY 36 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Steel Decking Under Turbine Deck North Extension INTENT:

Install decking under the north turbine deck extension to reduce the risk to important equipment under the deck from any heavy load drop in this area.

STATUS WITH RESPECT TO CURRENT PLANT:

Current plant has no such protection, but has-not experienced any drops of loads in this area that caused the type of damage that would be protected against.

DEGREE OF IMPROVEMENT:

Weak, due to plant and industry load handling history and currently followed procedures designed to minimize risk.

PROBABILITY OF EVENT:

Low

PRIORITY 37 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP VI-7.C.2, Upgrade Redundant N2 Supply to FCV 1115 D, E, F (Partial Single Failure)

INTENT:

Improve equipment on backup nitrogen supply by installing safety grade equipment.

STATUS WITH RESPECT TO CURRENT PLANT:

Existing system contains equipment not demonstrated qualified.

DEGREE OF IMPROVEMENT:

Improvement would ensure system is qualified.

PROBABILITY OF EVENT:

Same as any LOCA/HELB where recirculation may be required.

PRIORITY 38 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Upgrade Temporary Volume Control Tank Level Instrumentation INTENT:

Temporary local volume control tank level instrumentation was installed for phase 1 of fire protection. This level instrumentation is the subject of a non-conformance report and is required to be upgraded to improve local level indication.

STATUS WITH RESPECT TO CURRENT PLANT:

Instrumentation is not installed per current criteria.

DEGREE OF IMPROVEMENT:

Minor. Instrumentation continues to work and is used only for safe shutdown in the event of fire.

PROBABILITY OF EVENT:

Fires have occurred but this instrumentation is only required when normal safe shutdown capability is in jeopardy.

PRIORITY 39 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Seismic Upgrade of Electrical Raceways INTENT:

Complete upgrade of electrical raceways to ensure capability to withstand 0.67g Housner earthquake.

STATUS WITH RESPECT TO CURRENT PLANT:

Seismic upgrade of raceways is 80% complete. All tray tiedowns will be installed.

DEGREE OF IMPROVEMENT:

Small since key elements have been completed and raceway tests show that raceways do not fail even in large earthquakes.

PROBABILITY OF EVENT:

Probability of 0.67g earthquake is very low.

PRIORITY 40 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP III-5.B Pipe Break Outside Containment -

Pipe Whip Restraints, Barriers, etc.

INTENT:

Provide protection against pipe breaks outside containment by relocation, restraint, or other protection of equipment required to achieve a safe shutdown condition.

STATUS WITH RESPECT TO CURRENT PLANT:

Plant was not specifically designed for protection from high energy line breaks. Alternate means of shutdown may be available (e.g., feed and bleed).

DEGREE OF IMPROVEMENT:

Substantial improvement in protection of equipment in the event of a particular pipe break provided leak-before-break cannot be demonstrated.

PROBABILITY OF EVENT:

Ruptures and breaks in some NSR piping has occurred at other plants and at plants in other industries, but the lines considered in this analysis are not high energy lines which were previously analyzed and resolved in phase 1 work in 1973.

PRIORITY 41 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Control Room Design Review INTENT:

Review the current plant control room configuration using current human factors knowledge and recommend high benefit modifications to enhance control room operability.

STATUS WITH RESPECT TO CURRENT PLANT:

Current plant is familiar to operators and improvement cannot be directly measured.

DEGREE OF IMPROVEMENT:

Minor PROBABILITY OF EVENT:

Control room is used to monitor and control almost all events.

PRIORITY 42 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP VIII-3.B, DC Power System Bus Voltage Monitoring and Annunciation INTENT:

Provide sufficient DC power sytem monitoring and annunciation so that the operator can (1) prevent the loss of an emergency bus or (2) take timely corrective action in the event of a loss of an emergency bus.

STATUS WITH RESPECT TO CURRENT PLANT:

Current plant monitoring and annunciation is considered to provide adequate information to satisfy the safety concerns of Topic VIII-3.B.

DEGREE OF IMPROVEMENT:

Weak due to low probability of event and perceived adequacy of existing capability.

PROBABILITY OF EVENT:

Station blackout -

low.

PRIORITY 43 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP III-7.B Design Codes, Criteria and Load Combinations Containment LOCA & Seismic Analysis INTENT:

Analyze the containment for combined effect of dead load, SSE loads, and pressure and thermal loads due to either LOCA or MSLB, whichever is more limiting. Verify that critical buckling stress in sand filled transistion zone is within acceptable limits.

STATUS WITH RESPECT TO CURRENT PLANT:

San Onofre Unit 1 is an older nuclear plant, which went into commercial operation in January, 1968. The buckling problem is related to its special containment configuration. Conservative analysis shows containment may not meet criteria.

DEGREE OF IMPROVEMENT:

Weak, due to low probability of SSE combined with LOCA/MSLB and conservatisms in analysis.

PROBABILITY OF EVENT:

Low

PRIORITY 44 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEPVIII-4, Electrical Penetration of Containment INTENT:

Modify the backup protection for the safety-related equipment inside containment to ensure a fault current will not affect the isolating ability of the electrical penetrations.

STATUS WITH RESPECT TO CURRENT PLANT:

Analysis which determined penetrations may fail is conservative with regard to assumptions. Failure of penetration could result in only minor breach of containment.

DEGREE OF IMPROVEMENT:

Minimum improvement as demonstrated by NRC PRA.

PROBABILITY OF EVENT:

Low as demonstrated by NRC PRA.

F*

e PRIORITY 45 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Environmental Qualification INTENT:

Ensure qualification of equipment required for shutdown and accident mitigation in accordance with NRC DOR Guidelines.

STATUS WITH RESPECT TO CURRENT PLANT:

Justifications for continued operation has been provided to the NRC by letter dated February 24, 1982.

DEGREE OF IMPROVEMENT:

Substantial improvement as it relates to equipment reliability and availability. Minor as it relates to other areas.

PROBABILITY OF EVENT:

Low since alternate means have been demonstrated in equipment justifications.

PRIORITY 46 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Valve Seat Upgrade/Replacement CV 525 & 527 INTENT:

Replace existing seats with upgraded seats with qualified material.

STATUS WITH RESPECT TO CURRENT PLANT:

Existing seats in question have not been demonstrated unqualified.

Obtaining documentation from Gulf and Western/DuPont has been difficult.

DEGREE OF IMPROVEMENT:

Some improvement since it would be assured that seat material is qualified for containment.

PROBABILITY OF EVENT:

Low since additional valves are located outside containment for isolation.

PRIORITY 47 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Replacement of SV99 Actuation Circuit INTENT:

Remove acutation of SV 99 from existing monitor to newly installed monitor.

STATUS WITH RESPECT TO CURRENT PLANT:

The existing system is operational;.however, monitor is old and has accuracy problem.

DEGREE OF IMPROVEMENT:

Improve the reliability of the system and provide operation and maintenance relief.

PROBABILITY OF EVENT:

Downscale failure event has occurred wheter instrument has failed and release was not monitored.

PRIORITY 48 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP VI-4, Containment Isolation Electrical (Partial)

Provide CIAS for Inside RCSS Valves and Eliminate Override on Outside Valves INTENT:

Provide automatic isolation for the six inside isolation valves of the RCSS in order to meet GDC 55 and eliminate override capability of outside isolation valves because the need to obtain post-accident reactor coolant samples will be done by the PASS and these do not need to have override capabilities.

STATUS WITH RESPECT TO CURRENT PLANT:

Inside isolation valves have remote manual operation and are normally closed. Outside isolation valves has CIAS, are normally closed, and have normally closed manual valves at sample hood.

DEGREE OF IMPROVEMENT:

Weak due to reliability of present configuration.

PROBABILITY OF EVENT:

Low

(A 0

PRIORITY 49 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE: SEP VI-4, Containment Isolation Systems INTENT:

Upgrade containment penetrations to comply with the General Design Criteria of 10 CFR 50, Appendix A.

STATUS WITH RESPECT TO CURRENT PLANT:

Types of valves and location of valves on several penetrations do not comply with the GDC.

DEGREE OF IMPROVEMENT:

Weak due to only a small reduction in failure probability will be realized by changing to the recommended configurations.

PROBABILITY OF EVENT:

Weak due to reliability of present configuration.

PRIORITY 50 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Automatic Trip of Reactor Coolant Pumps INTENT:

Review current design with the owner's group and recommend any modifications (procedurally and hardware) that will ensure that the reactor coolant pumps are running or not running as appropriate during the applicable design basis accidents.

STATUS WITH RESPECT TO CURRENT PLANT:

Current plant shows good performance during SBLOCA's for which other plants have a problem (i.e., preferred to run during SGTR but not during SBLOCA's).

San Onofre Unit 1 can withstand RCP operation during SBLOCA's.

DEGREE OF IMPROVEMENT:

Low PROBABILITY OF EVENT:

Low

PRIORITY 51 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

CVCS Valves MOV-LCV-1100 B, C, D INTENT:

Modify control circuit such that valves remain in their safety position following termination of safety injection signals.

Valves would now automatically return to their pre-SIS position.

STATUS WITH RESPECT TO CURRENT PLANT:

Administrative procedures are in place which require these valves to have their position maintained when safety injection is terminated.

DEGREE OF IMPROVEMENT:

Minor. Administrative procedures are explicit. Valves change source of water to charging pump suction from Refueling Water Storage Tank to Volume Control Tank.

PROBABILITY OF EVENT:

Low

PRIORITY 52 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

12 kV Construction Power System Improvements INTENT:

Provide ground fault detection and improved isolation for 12 kV/480 V transformer used as backup power supply for fire protection.

STATUS WITH RESPECT TO CURRENT PLANT:

Will improve availability of backup power supply and improve personnel safety.

DEGREE OF IMPROVEMENT:

Minor PROBABILITY OF EVENT:

Low

PRIORITY 53 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP VI-4, Containment Isolation Electrical (Partial)

Diesel Generator Radiator Fans Loading INTENT:

Make diesel generator radiation fans which load on emergency power to be placed on line with a delay after SIS/LOP or immediately due to SIS with no loss of offsite power.

STATUS WITH RESPECT TO CURRENT PLANT:

Fans are currently actuated immediately.

DEGREE OF IMPROVEMENT:

Weak due to the large capacity of the diesel generators.

PROBABILITY OF EVENT:

Very low

PRIORITY 54 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP VIII-l.A, Potential Equipment Failures Associated with Degraded Grid Voltage INTENT:

To upgrade the plants protection against degraded voltage conditions to ensure the electrical equipment (i.e., motors, MOV's, etc.) are not damaged by the degraded voltage.

STATUS WITH RESPECT TO CURRENT PLANT:

Current plant is designed to protect against.extreme conditions, but not dips in voltage that are small and could degrade operating equipment.

DEGREE OF IMPROVEMENT:

Existing equipment provides protection but is not as sophisticated as new single failure proof system.

PROBABILITY OF EVENT:

Low

PRIORITY 55 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Waste Gas Decay Tank Monitoring Instrumentation INTENT:

Provide instrumentation to monitor waste gas releases to the environment. System has problems with leaks which must be assumed to go to atmosphere instead of other tanks.

STATUS WITH RESPECT TO CURRENT PLANT:

Instrumentation does not exist to assess loss of waste gas to the local environment. Leakage must be calculated from measured variables.

DEGREE OF IMPROVEMENT:

Strong improvement in ability to determine release to environment.

PROBABILITY OF EVENT:

Minor loss of waste gas has occurred.

PRIORITY 56 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

NIS Rockbestos Cable Replacement INTENT:

Replace Rockbestos Cable which does not satisfy temperature requirements with a qualified cable.

STATUS WITH RESPECT TO CURRENT PLANT:

System not required for post-accident operation, cable is functional during normal operation.

DEGREE OF IMPROVEMENT:

Some improvement in ensuring that qualified cable is installed on NIS.

PROBABILITY OF EVENT:

System not required post-accident.

PRIORITY 57 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Condensate Storage Tank Flooding Potential INTENT:

Evaluate condensate storage tank to determine consequences of failure due to an earthquake.

STATUS WITH RESPECT TO CURRENT PLANT:

A.new auxiliary feedwater tank has been installed. Condensate storage tank is outside.

DEGREE OF IMPROVEMENT:

Small since the only potentially damaging failure would appear to be equipment located inside south turbine building extension. This equipment is not required to get to safe shutdown.

PROBABILITY OF EVENT:

Probability of 0.67g earthquake is very low.

PRIORITY 58 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP IX-3, Station Service and Cooling Water Systems (Partial)

INTENT:

Assure component cooling water system and the saltwater cooling system have the capability to perform required safety functions (this item excludes Priority 9 concerns). This includes evaluation of component cooling water passive failures, closure of tsunami gates post accident and loss of bearing flush water flow.

STATUS WITH RESPECT TO CURRENT PLANT:

Component cooling water system is not fully single-passive failure proof, system realignment is being analyzed as acceptable, tsunami gates have never been required and loss of bearing flush water has been demonstrated acceptable for long periods of time.

DEGREE OF IMPROVEMENT:

Component cooling passive failure - system is low pressure and temperature, failure is unlikely. Closure of tsunami gates would still allow auxiliary pump to be available and some amount of cooling water would get through gates.

PROBABILITY OF EVENT:

Passive failure of CCW system is a low probability event. Closure of tsunami gates post accident is low probability.

PRIORITY 59 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP VI-4 Containment Isolation Electrical (Partial)

Re-Letter "Block SIS" Annunciator Window INTENT:

Re-letter the "Block SIS" Annunciator Window to indicate that Containment Spray System has also been blocked and the Safety Injection input to Containment Isolation System has also been blocked. This modification will provide indication to the operator that these additional signals have been blocked or partially blocked.

STATUS WITH RESPECT TO CURRENT PLANT:

Annunciator window currently indicates only that SIS has been blocked.

DEGREE OF IMPROVEMENT:

Weak because will not affect system reliability and due to established programs. Operators are aware of effects of blocking SIS.

PROBABILITY OF EVENT:

Low

PRIORITY 60 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Seismic Upgrade of South Turbine Extension INTENT:

Complete upgrade of south turbine extension to use capability to withstand 0.67g Housner earthquake.

STATUS WITH RESPECT TO CURRENT PLANT:

All.upgrades except one foundation and one brace have been completed. No equipment is located in this structure which is required to get to safe shutdown.

DEGREE OF IMPROVEMENT:

Small due to significant bracing already installed.

PROBABILITY OF EVENT:

Probability of 0.67g earthquake is very low.

K 7

PRIORITY 61 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP III-1, Classification of Structures, Systems, and Components INTENT:

To deterine whether San Onofre Unit 1 as an as-built facility meets quality standards required today for new nuclear plants.

For this purpose, additional design data is needed in the following areas:

fracture toughness requirements, radiography requirements, pressure vessels, pipings, valves, pumps, storage tanks.

STATUS WITH RESPECT TO CURRENT PLANT:

San Onofre Unit 1, is an older nuclear plant (date of initial criticality June 1976), and was designed to quality standards in effect in the 1960's. Quality standards required today for new plants are considered more stringent. Also, the documentation in the areas of concern listed above is more complete for new plants. Review to date has shown that changes are of minor significance.

DEGREE OF IMPROVEMENT:

Weak. This effort will insure confidence in the as-built capability of the plant. Review of material to date has not, however, identified anything of significant safety concern. Failure to find documentation does not mean data is not suitable.

PROBABILITY OF EVENT:

N/A

PRIORITY 62 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Safety Parameter Display System INTENT:

Install a system to satisfy the NRC's requirement of NUREG-0737, Supplement 1.

STATUS WITH RESPECT TO CURRENT PLANT:

The current plant has a system that functions to transmit information to the TSC and EOF, but does not entirely meet the requirements of NUREG-0737, Supplement 1.

DEGREE UF IMPROVEMENT:

The current control room has 15 years of operating history and the existing display system provides the TSC people with adequate information to respond in an emergency. Accordingly, the degree of improvement is small.

PROBABILI1Y OF EVENT:

Low

PRIORITY 63 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Inadequate Core Cooling INTENT:

Provide inadequate core cooling instrumentation in PWR's.

STATUS WITH RESPECT TO CURRENT PLANT:

The current plant has core-exit thermocouples and a subcooling margin monitor to support the emergency procedures.

DEGREE OF IMPROVEMENT:

Minor, due to the current plant hardware status and emergency procedures.

Instrumentation would provide information redundant to what operator already knows.

PROBABILITY OF EVENT:

Low

0 PRIORITY 64 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP XV-1, Increase in Feedwater Flow INTENT:

Install main feedwater pump trip on high steam generator level.

STATUS W11H RESPECT TO CURRENT PLANT:

Provide automatic trip of pumps to prevent steam generator overfill rather than relying on operator action. Operators currently have several minutes to diagnose problem. Past SI events have shown that overfill will lead to generation of an SI signal which would terminate feedwater flow.

DEGREE OF IMPROVEMENT:

Small due to existing time and SI system initiation.

PROBABILITY OF EVENT:

Low

PRIORITY 65 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP VII-3, Systems Required for Safe Shutdown (Redundant Component Cooling Level Instrumentation)

INTENT:

All open items have been addressed or resolved by other topics with the exception of level monitoring instrumentation on the CCW surge tank.

STATUS WITH RESPECT TO CURRENT PLANT:

Operator inspects tank level once every shift. Alarms available for the tank in the control room, and loss of water would lead to other symptoms which would alert the operator.

DEGREE OF IMPROVEMENT:

Some improvement to monitoring of surge tank by adding redundant instrumentation.

PROBABILITY OF EVENT:

Loss of CCW has not occurred. System is low pressure and temperature.

PRIORITY 66 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Radiological Effluent Technical Specification Modifications INTENT:

Implement Technical Specifications which require monitoring of plant effluents as required by 10 CFR 50, Appendix I.

STATUS WITH RESPECT TO CURRENT PLANT:

Detailed radiological effluent Technical Specifications are not in effect. Addition of these Technical Specifications would not, however, actually change what would be emitted from plant, but would provide more detailed monitoring.

DEGREE OF IMPROVEMENT:

Improvement is primarily in monitoring releases but would not significantly affect degree of releases.

PROBABILITY OF EVENT:

Required for normal and abnormal releases.

PRIORITY 61 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Post Accident Sampling 02 and Cl Monitoring INTENT:

To add an undiluted grab sample facility and an inline 02 monitor for post-accident damage assessment.

STATUS WITH RESPECT TO CURRENT PLANT:

Currently total dissolved gases and a diluted sample facility are available. Thus, this modification is an accuracy improvement only.

This system is only for post accident monitoring.

DEGREE OF IMPROVEMENT:

Not much improvement to plant safety as these two parameters are mostly post-accident damage assessment, not mitigating.

PROBABILITY OF EVENT:

Low

PRIORITY 68 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Improvements to Operational Radiation Monitoring System INTENT:

Upgrade the existing operational radiation monitoring system.

STATUS WITH RESPECT TO CURRENT PLANT:

Existing system is functional. However older vintage is difficult to get replacement parts. Downscale failure would result in false monitoring.

DEGREE OF IMPROVEMENT:

Operation and maintenance would be substantially improved. There would be no more downscale failures and the availability would be improved.

PROBABILITY OF EVENT:

Downscale failure event has occurred where release was not indicated.

PRIORITY 69' INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP II-3.A, II-3.B and III-3.A, Ventilation Building and Fuel Storage Building Rooftop Drainage INTENT:

Assure precipitation up to probable maximum precipitation (PMP) does not adversely impact the safety-related features of the fuel storage building and the ventilation equipment building.

STATUS WITH RESPECT TO CURRENT PLANT:

Ponding loads due to PMP may exceed the current fuel storage building and ventilation equipment building rooftop capabilities. Failure modes are not expected to be catastrophic and would not prevent safety functions.

DEGREE OF IMPROVEMENT:

Low - Existing scuppers provide substantial protection and failure mode of roof is not expected to be catastrophic.

PROBABILITY OF EVENT:

Probability of precipitation resulting in rooftop ponding in excess of the current design bases is low.

PRIORITY 70 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

Solidified Resin Storage Facility INTENT:

Expand the storage capacity and handling of spent resins to be able to store several years of waste.

STATUS WITH RESPECT TO CURRENT PLANT:

Plant currently ships resins to offsite facilities for storage/disposal.

DEGREE OF IMPROVEMENT:

Current capacity is only one year.

PROBABILITY OF EVENT:

No events are associated with this modification.

PRIORITY 71 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP V-10.A, Residual Heat Removal Heat Exchanger Tube Failures INTENT:

Include monitoring of primary side for chlorides in the Technical Specifications. Expand the monitoring of the CCW system to include chlorides and monitoring during shutdown.

Install radiation monitor on SWC or include CCW radiation monitor in Technical Specifications.

STATUS WITH RESPECT TO CURRENT PLANT:

Water is currently monitoried by procedure. Radiation monitor exists and is being identified in new Technical Specifications.

DEGREE OF IMPROVEMENT:

No improvement.

PROBABILITY OF EVENT:

Low

PRIORITY 72 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP V-5, Reactor Coolant Pressure Boundary Leakage Detection INTENT:

Provide improved methods of monitoring leaks from the RCS to the containment and to other systems.

STATUS WITH RESPECT TO CURRENT PLANT:

Several methods of determining leakage are in place and are accurate but do not completely meet Regulatory Guide 1.45.

DEGREE OF IMPROVEMENT:

Very small.

Improvements would add primarily to "time to achieve" sensitivity but not to sensitivity itself.

PROBABILITY OF EVENT:

Low. Though leaks do occur, the current capability to discover and monitor them is good.

PRIORITY 73 INTEGRATED LIVING SCHEDULE REGULATORY PROJECT

SUMMARY

AND BASIS FOR RANKING TITLE:

SEP III-8.A, Loose Parts Monitoring System INTENT:

To install a loose parts and core barrel vibration monitoring system.

STATUS WITH RESPECT TO CURRENT PLANT:

Systems to monitor vibration does not exist but degraded operation of any components/systems may be noticed by alarms for a particular system.

DEGREE OF IMPROVEMENT:

Plant and industry history shows that problems caused by loose parts are infrequent and have never led to an off-normal transient.

PROBABILITY OF EVENT:

Low