ML13310B159

Advises That Revised Schedule for Capital Projects to Implement Proposed Integrated Living Schedule Unacceptable. Proposed Schedule Indicates Delays in Implementing Mods Prescribed in Commission Regulations

ML13310B159
Person / Time
Site:	San Onofre
Issue date:	01/20/1984
From:	Eisenhut D Office of Nuclear Reactor Regulation
To:	Baskin K Southern California Edison Co
References
TAC-54376 LSO5-84-01-034, LSO5-84-1-34, NUDOCS 8401250124
Download: ML13310B159 (6)

Text

oV UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 January 20, 1984 Docket No. 50-206 LS05-84-01-034 Mr. K. Baskin, Vice President Nuclear Engineering Licensing and Safety Department Southern California Edison Company 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

SUBJECT:

SOUTHERN CALIFORNIA EDISON COMPANY'S PROPOSED INTEGRATED LIVING SCHEDULE San Onofre Nuclear Generating Station, Unit No. 1 By letter dated December 6, 1983, you forwarded a revised schedule for the total scope of capital projects identified for implementation at San Onofre Unit No. 1. Your letter also included summaries of each of the regulatory projects included in the schedule. Your schedule extends to the year 2010.

We note that this schedule is about 20 years longer than the preliminary' schedule that was discussed with NRC management last year and presented in your June 17, 1983 letter. The NRC staff has reviewed your schedule and, for the reasons cited belowi finds that the schedule as proposed is not acceptable.

(Your proposed schedule shows significant delays in implementing facility) modifications that are prescribed in Commission regulations (e.g. environ mental qualification of safety related electrical equipment with a proposed completion date of 2007 and Appendix R to 10 CFR Part 50 safe shutdown fire protection features with a proposed completion date of 2000). The NRC staff cannot approve schedules that are not in compliance with the regulations; rather, requests for exemption should be submitted for Commission review.

In addition, the brief summary of each regulatory project does not provide adequate justification for the proposed delay in implementation. Finally, the schedule for completion of the items is unreasonably long. In this regard, we note that about one-half of the regulatory projects are those

.associated with modifications resulting from the Systematic Evaluation Program (SEP). As we understand, your estimates for cost and schedule for these items are based on meeting current criteria. As you know, during the integrated assessment phase of the SEP, we will assess the need for and extent of backfitting these SEP items.

We would expect that some of the SEP.related items will be reduced in scope as a result of the integrated assessment. A shorter schedule should result.

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January 20, 1984 Although we do not find your proposed schedule acceptable, we reiterate our position that an integrated schedule for capital projects is desirable.

The NRC staff is prepared to review any revision to your proposed schedule that may be made in light of the above comments.

Sincerely, DarrelG. E 0 zisenghAb Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation cc:

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Mr. K. Baskin cc Charles R. Kocher, Assistant General Counsel James Beoletto, Esquire Southern California Edison Company Post Office Box 800 Rosemead, California 91770 David R. Pigott Orrick, Herrington & Sutcliffe 600 Montogmery 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:

Joseph 0. Ward, Chief Radiation Control Unit Radiological Health Section 714 P Street, Room 498 Sacramento, California 95814 U.S. Environmental Protection Agency Region IX Office ATTN:

Regional Radiation Representative 215 Freemont Street San Francisco, California 94111 John B. Martin, Regional Administrator Nuclear Regulatory Commission, Region V 1450 Maria Lane Walnut Creek, California 94596

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.0 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, 0. C. 20555 January 20, 1984 Docket No. 50-206 LS05-84-01-034 Mr. K. Baskin, Vice President Nuclear Engineering Licensing and Safety Department Southern California Edison Company 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

SUBJECT:

SOUTHERN CALIFORNIA EDISON COMPANY'S PROPOSED INTEGRATED LIVING SCHEDULE San Onofre Nuclear Generating Station, Unit No. 1 By letter dated December 6, 1983, you forwarded a revised schedule for the total scope of capital projects identified for implementation at San Onofre Unit No. 1. Your letter also included summaries of each of the regulatory projects.included in the schedule. Your schedule extends to the year 2010.

We note that this schedule is about 20 years longer than the preliminary schedule that was discussed with NRC management last year and presented in your June 17, 1983 letter. The NRC staff has reviewed your schedule and, for the reasons cited below, finds that the schedule as proposed is not acceptable.

Your proposed schedule shows significant delays -in implementing facility modifications that are prescribed in Commission regulations (e.g. environ mental qualification of safety related electrical equipment with a proposed completion date of 2007 and Appendix R to 10 CFR Part 50 safe shutdown fire protection features with a proposed completion date of 2000). The NRC staff cannot approve schedules that are not in compliance with the regulations; rather, requests for exemption should be submitted for Commission review.

In addition, the brief summary of each regulatory project does not provide adequate justification for the proposed delay in implementation.

Finally, the-schedule for completion of the items is unreasonably long. In this regard, we note that about one-half of the regulatory projects are those associated with modifications resulting from the Systematic Evaluation Program (SEP). As we understand, your estimates for cost and schedule for these items are based on meeting current criteria. As you know, during the integrated assessment phase of the SEP, we will assess the need for and extent.of backfitting these SEP items. We would expect that some of the SEP related items will be reduced in scope as a result of the integrated assessment. A shorter schedule should result.

January 20, 1984 Although we do not find your proposed schedule acceptable, we reiterate our position that an integrated schedule for capital projects is desirable.

The NRC staff is prepared to review any revision to your proposed schedule that may be made in light of the above comments.

incerely, r G u t 5 Direc arrell G. ise ut, Director Division of Licensing Office of Nuclear Reactor Regulation cc: See next page

Mr. K. Baskin cc Charles R. Kocher, Assistant General Counsel James Beoletto, Esquire Southern California Edison Company Post Office Box 800 Rosemead, California 91770 David R. Pigott Orrick, Herrington & Sutcliffe 600 Montogmery 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:

Joseph 0. Ward, Chief Radiation Control Unit Radiological Health Section 714 P Street, Room 498 Sacramento, California 95814 U.S. Environmental Protection Agency Region IX Office ATTN:

Regional Radiation Representative 215 Freemont Street San Francisco, California 94111 John B. Martin, Regional Administrator Nuclear Regulatory Commission, Reaion V 1450 Maria Lane Walnut Creek, California 94596