ML13310B417
| ML13310B417 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/23/1984 |
| From: | Baskin K Southern California Edison Co |
| To: | |
| Shared Package | |
| ML13310B414 | List: |
| References | |
| TAC-54376 NUDOCS 8405250068 | |
| Download: ML13310B417 (14) | |
Text
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA EDISON
)
COMPANY and SAN DIEGO GAS & ELECTRIC COMPANY )
for a Class 104(b) License to Acquire,
) DOCKET NO. 50-206 Possess, and Use a Utilization Facility as
)
-Part of Unit No. 1 of the San Onofre Nuclear ) Amendment Application No. 119 Generating Station
)
SOUTHERN CALIFORNIA EDISON COMPANY and SAN DIEGO GAS & ELECTRIC COMPANY, pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 119.
This amendment application consists of Proposed Change No. 134 to Provisional Operating License No. DPR-13. This Proposed Change revises Provisional Operating License No. DPR-13, Section 3, "Contents and Conditions," to establish a program for the management of backfits at San Onofre Unit 1.
The proposed Condition 3.3 requires periodic updates and reports regarding schedules for all capital backfits at San Onofre Unit 1. There will be three schedules with differing degrees of rigidity built into each in order to reflect the different levels of NRC requirements for each category of backfits.
PD340 I 05000206 PD
-2 Based on the safety analysis provided in the Description of Proposed Change and Safety Analysis, it is concluded that (1) this proposed change does not involve an unreviewed safety question as defined in 10 CFR 50.59, nor does it present significant hazards considerations not described or implicit in the Final Safety Analysis, and (2) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed change.
Pursuant to 10 CFR 170.22, Amendment Application No. 119 consisting of Proposed Change No. 134 is determined to constitute a Class II amendment.
The basis for the determintion is that the Proposed Change provides a condition to establish a program for the administration of backfits at San Onofre Unit 1. The fee of $1,200 corresponding to this determination is herewith remitted as required by 10 CFR 170.22.
-3 Subscribed on this od73 day of
______ff Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY By Z
Kenneth P. Baskin Vice President Subscribed and sworn to before me this 4,3A4' day of OFFICIAL SEAL AGNES CRABTREE NOTARY PUBLIC -
CALIFORNIA PRINCIPAL OFCEiN LOS ANGELES COUNTY MY Commission Expires Aug. 27, 1986 Los A geles, State of California Charles R. Kocher James A. Beoletto Attorneys for Southern California Edison Company By Ja sA. Beolet o
-4 Subscribed on this 21 day of
/ cff Respectfully submitted, SAN DIEGO GAS & ELECTRIC COMPANY By J. C. Holcombe Vice President Subscribed and sworn to before me this
~~ day of__
ary Public in and fo; the 6unty of San Diego, State of California OFFICIAL SEAL LORAINE E. GRAY NOTARY PUBLIC CALIFORNIA David R.
Pigott PRINCIPAL OFFICE IN Samuel B.
Casey SAN DIEGO COUNTY MY Commission Exp. April 6 1986 Orrick, Herrington & Sutcliffe Attorneys for San Diego Gas & Electric Company By David R. Pigott
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of SOUTHERN
)
CALIFORNIA EDISON COMPANY
)
and SAN DIEGO GAS & ELECTRIC
)Docket No. 50-206 COMPANY (San Onofre Nuclear
)
Generating Station Unit No. 1 CERTIFICATE OF SERVICE I hereby certify that a copy of Amendment No. 119 was served on the following by deposit in the United States Mail, postage prepaid, on the 23rd day of May
, 1984.
Henry J. McGurren, Esq.
Staff Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20545 David R. Pigott, Esq.
Samuel B. Casey, Esq.
Orrick, Herrington & Sutcliffe 600 Montgomery Street San Francisco, California 94111 John V. Morowski Bechtel Power Corporation P.O. Box 60860, Terminal Annex Los Angeles, California 90060 Michael L. Mellor, Esq.
Thelen, Marrin, Johnson & Bridges Two Embarcadero Center San Francisco, California 94111 Huey Johnson Secretary for Resources State of California 1416 Ninth Street Sacramento, California 95814 Janice E. Kerr, General Counsel California Public Utilities Commission 5066 State Building San Francisco, California 94102
-2
- 3. Rengel Atomic Power Division Westinghouse Electric Corporation Box 355 Pittsburgh, Pennsylvania 15230 A. I. Gaede P.O. Box 373 San Clemente, California 92672 Frederick E. John, Executive Director California Public Utilities Commission 5050 State Building San Francisco, California 94102 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 So e A.
EBeoled o
As istant Counsel1 Sohern California Edison Company
DESCRIPTION OF PROPOSED CHANGE NO. 134 AND SAFETY EVALUATION PROVISIONAL OPERATING LICENSE DPR-13 This is a request to revise Section 3, "Contents and Conditions," of the Provisional Operating License No. DPR-13 for the San Onofre Nuclear Generating Station, Unit 1 to include Subsection 3.3, "Integrated Living Schedule of Backfits."
Description Part of the "Plan for Managing Plant Retrofit" at the San Onofre Nuclear Generating Station, Unit 1 is the development of a method for determining the implementation schedules of all capital backfits. The program described herein is consistent with the recommendations of Generic Letter 83-20, "Integrated Scheduling for Implementation of Plant Modifications," from Darrell G. Eisenhut, to all Operating Reactor Licensees and Holders of Construction Permits, dated May 9, 1983. The Integrated Living Schedule will be incorporated into the license, as a condition, to codify the method by which the schedules for backfits will be determined. Precedents as license conditions have been demonstrated with the Duane Arnold Amendment, dated May 3, 1983, and the Boston Edison Company Application for Amendment, dated July 5, 1983.
The license condition will make enforceable by the NRC the implementation dates of those backfits required by Rule, Regulation or Order, but allow for flexibility in the implementation of other backfits.
Existing Condition There is no existing condition concerning the implementation schedule for backfits at the unit.
Proposed Condition 3.3 Integrated Living Schedule of Backfits
- 1. Southern California Edison Company shall implement a plan for the scheduling of all capital backfits, both of regulatory and betterment origin based on the Integrated Living Schedule Program Plan -("The Plan" - copy attached and to be submitted with the Application for Amendment).
- a. The Plan shall be followed by the licensee from and after the effective date of this Amendment.
- b. The licensee is required to maintain current revisions of, and provide reports regarding schedules, by refueling outage of implementation, associated with the Plan in accordance with the terms of the Plan and failure to do so shall constitute a violation of this license condition.
-2 C. Dates specified in Schedule A shall be changed only in accordance with applicable NRC procedures.
Changes to dates for completion of items identified in Schedules B and C do not require a license amendment. Failure to complete items listed in the schedules in accordance with dates there specified shall not constitute a violation of this license condition, but may constitute a violation of any regulations, order or license conditions imposing such date.
- 2. This license amendment shall be effective until (date to be set for a 2 year effective period) subject to renewal upon application by the licensee.
Safety Evaluation The proposed change discussed above is deemed not to constitute a significant hazards consideration as it does not involve any aspects of the operation of the plant, nor does it limit or restrict in any way any other condition.of the license or Technical Specification. This is further demonstrated by the responses to the following questions:
- 1. Question Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequence of an accident previously evaluated?
Response: No This proposed change is administrative and it does not affect any hardware changes or accident analyses. Therefore, it does not increase the probability or consequence of any previously evaluated accident.
- 2. Question Will operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No Being administrative, this change can have no affect on any accident analysis. There will not be hardware changes to the plant caused by this amendment. There is no possibility that this Proposed Change will create a new or different kind of accident.
-3
- 3.
Question Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?
Response: No This change is administrative only and does not affect any accident analysis nor does it of itself involve any modification to the plant. Therefore, no reduction in a margin of safety will occur.
This Proposed Change is administrative, similar to example (i) of the "Examples of Amendments That are Considered Not Likely to Involve Significant Hazards Considerations" as published in 48 FR 14864 dated April 6, 1983. The change will establish an administrative program for reporting scheduling changes and maintaining current scheduling information on the capital backfits planned for the unit. The purpose of the program is to add stability and predictability to the backfitting process in order to obtain the optimum enhancement of safety from the scheduled backfits.
Safety and Significant Hazards Determination Based on the safety analysis, it is concluded that:
- 1. the Proposed Change does not constitute a significant hazards consideration as defined by 10 CFR 50.92;
- 2. there is reasonable assurance that the health and safety of the public will not be endangered by the proposed change; and
- 3. this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Environmental Statement.
GEH:1475F INTEGRATED LIVING SCHEDULE PROGRAM PLAN SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 1 I. INTRODUCTION This document provides the methodology to be used in determining the implementation schedules of capital projects at San Onofre Unit 1 in accordance with the provisions of License Condition 3.J.
The program has as its goal the implementation of capital backfits in a stable controllable manner with the implementation of projects with the greatest potential for enhancing the safe operation of the.unit generally given highest priority. The program will be used to determine the potential for enhancing safe plant operation of both projects of regulatory origin and betterment origin.
The lists for each of these categories will be evaluated separately and scheduled with implementation resources allocated 90% to regulatory related projects and 10% to plant betterment related projects.
The program reflects the limited financial and manpower resources available and that a limit must be placed on the on-site manpower necessary to efficiently implement the modifications. The plan provides for integration of all future identified work into one comprehensive schedule and it has built-in mechanisms for changes to the schedule when new modifications are identified or when key program milestones cannot be achieved due to considerations beyond the control of SCE.
II.
SUMMARY
OF PRIORITY DETERMINATION The currently identified scope of backfits when scheduled using normal constraints on site manpower capabilities extends over a period of longer than four outages as demonstrated in initial schedules presented to NRC management early in 1983. This demonstrates the need for giving implementation priority to those projects which have the greatest potential for enhancing the safe operation of the plant. For this purpose, the Westinghouse Analytical Ranking Process or an equivalent safety ranking method will be used to determine which projects should be implemented in a particular outage. Westinghouse has developed their process as a method for ranking projects according to the potential for enhancing plant safety and at the same time improving the operational characteristics of the plant.
This methodology or one equivalent will be used by SCE in determining any future changes to the schedule dictated by the identification of projects with safety and/or operational aspects warranting implementation in an early outage. A description of the Westinghouse Analytical Ranking process was submitted to the NRC by letter dated September 2, 1983 from Kenneth P. Baskin to H. R. Denton.
III. SCHEDULING Once the projects have been ranked according to their potential for enhancing safe plant operation, it is necessary to determine the outage in which the modifications will be implemented. The projects ranked
-2 highest will first be evaluated to determine whether they can be implemented in the next scheduled refueling outage. Projects will continue to be selected from the top of the ranked list and scheduled in the earliest outage in which implementation constraints of a three month outage have not been exceeded. These schedules will then be separated into three lists as briefly described below:
Schedule A All items which have implementation dates required by NRC Rules, Orders or License Conditions.
Schedule B Regulatory items (of either generic or plant specific nature) identified by the NRC which have implementation dates committed by Southern California Edison Company and which would result in plant modifications; or items perceived by Southern California Edison as prospective NRC requirements; or major tasks resulting from mandates of agencies other than NRC.
Schedule C Southern California Edison initiated plant betterment projects.
Schedule A dates may be modified only with prior NRC approval in accordance with existing NRC procedures. Changes in Schedule B dates require written notification to the NRC as described in Section V.
Schedule C dates may be changed at SCE discretion. Schedules A, B and C taken together, provide the basis for assessing the overall effects of changes to schedules and a departure point for discussion between the NRC and SCE regarding such changes, as discussed below.
IV. SCHEDULE MODIFICATIONS An important aspect of Southern California Edison's planning effort is the recognition that the schedules will need to be modified at times to reflect changes in regulatory requirements, to accommodate those activities that Southern California Edison finds necessary to improve plant efficiency and reliability, and to take into account delays resulting from events beyond SCE's control. It is important that the procedure used by Southern California Edison for changing the schedules be documented.*/ In addition, the NRC must play a role in the oversight of the scheduling process (and must, in fact, judge the acceptability of proposed date changes in Schedule A).
Accordingly, it is important that the NRC's role, and the interaction between the NRC and SCE be clearly defined, as discussed below.
- /
Schedules A, B and C will contain sufficient detail to identify those items with completion dates keyed to fuel cycle outages. In such cases, a change in outage period shall not be considered a schedule change.
-3 V. SOUTHERN CALIFORNIA EDISON COMPANY RESPONSIBILITIES The Integrated Living Schedule requires that SCE monitor the progress of the work undertaken, manage its activities to maintain the schedule, and act promptly to take necessary actions when a schedule change is needed.
A. Periodic Updating Southern California Edison will update Schedules A, 8 and C semi-annually and submit the revised schedules to the NRC, beginning six months following NRC approval of the Plan. In addition to updating the schedules, SCE will:
o Summarize progress in implementing NRC requirements concerning plant modifications.
o Identify changes since the last report.
o Summarize the reasons for schedule changes associated with Schedules A and B.
B. Changes to Schedules Changes to the schedules may arise from a variety of reasons, such as new work activities; modifications in the scope of scheduled work; problems in delivery, procurement, etc.; changes in NRC rules and regulations; or other NRC or SCE actions.
Where it is necessary to add a new work item or to change the schedule for an item, the following general guidance will be utilized to the extent appropriate:
o Determine the priority of the project, or changed priority, using the Westinghouse Analytical Ranking Process or an equivalent ranking method.
o Schedule the new or changed item to avoid rescheduling other items already well underway, if it can be reasonably achieved.
o Alter Schedule B and C items before Schedule A items unless priorities indicate that a Schedule A project should be rescheduled by appropriate Commission procedures.
o Select a schedule for the new or changed item which will help maintain an optimum integrated program of work.
As noted above, no changes will be made to Schedule A without prior NRC approval.
Should a change become necessary, it will only be proposed after Southern California Edison has determined that rescheduling of lower priority work either will not significantly assist in scheduling Schedule A without change, or that the safety, cost or schedule penalties from rescheduling lower priority work significantly outweigh the change in a Schedule A completion date.
-4 Southern California Edison will inform the NRC Project Manager when serious consideration is given to requesting a change in Schedule A. When SCE determines that a change in Schedule A is necessary, it will submit a written request for NRC approval in accordance with applicable procedures.
Work items in Schedule B may be rescheduled or work items may be added to Schedule B by Southern California Edison without NRC approval; however, SCE will inform the NRC Project Manager when serious consideration is given to significantly changing the schedule for or adding an item in Schedule B.
In addition, at least 30 days (unless otherwise agreed by the NRC Project Manager or unless circumstances beyond SCE's control arise within 30 days of the scheduled date) before SCE adopts a significant change for an item in Schedule B (as defined in Section III above), it will provide the NRC written notification thereof, including the reasons therefore and any compensatory actions instituted.
If not provided 30 days in advance, such notification will be-provided by SCE as promptly as practicable.
NRC may request further explanation or discussion concerning such change. In this event, discussions will be initiated with the NRC Project Manager. However, SCE changes in scheduled dates will be effective unless subsequently modified by SCE.
Work items in Schedule C may be rescheduled or work items may be added to Schedule C by Southern California Edison without NRC approval.
SCE will report on changes to Schedule C items in its semi-annual update to be provided in accordance with Section V.A above.
VI.
NRC REVIEW As pointed out in Section V.B above, changes to the schedules are inevitable. Action required by the NRC is discussed below:
A. Southern California Edison Originated Changes
- 1. Upon receipt from SCE of a request for modification of Schedule A, NRC will act promptly (consistent with resource availability and priority of other work) to consider and decide on the request in accordance with applicable procedures.
- 2. If the request for a modification of Schedule A is denied, the NRC shall promptly inform Southern California Edison and provide the reasons for denial.
- 3. NRC consideration of SCE changes in non-Schedule A items is covered by V.B.
-5 B. NRC Originated Changes (Schedule A)
It is recognized that formal NRC regulatory actions may:
(1) impose a new regulatory requirement with a fixed date or (2) establish a firm date for a previously identified regulatory requirement. In taking any such action, the NRC, to the extent consistent with its overall regulatory responsibilities and, unless public health, safety, or interest require otherwise, will take into account the impact of such action on SCE's ability to complete effectively the items on Schedules A, B and C, and, in consultation with SCE, will try to minimize such impact.
Although any formal regulatory action taken by the NRC will be effective in accordance with its terms without inclusion in Schedule A, the NRC and SCE recognize the desirability of incorporating such action into Schedule A, particularly in order to incorporate at the same time any other appropriate changes in the total integrated schedule program.
Accordingly, once such formal regulatory action is taken (or earlier, if practicable), the NRC will provide SCE a reasonable opportunity to propose overall changes in the total integrated schedule program which would most effectively accommodate such requirements.
Any resulting changes in items in Schedule A will be approved by NRC in accordance with established procedures, and will thereupon be reflected in a revised Schedule A submitted by SCE.
SCE will inform the NRC of any resulting changes in Schedule B in accordance with Section V. above.
C. New NRC Issues (Schedule B)
The NRC may, from time to time, identify new regulatory issues which may result in plant modifications.
For issues as to which NRC requests scheduling information, these issues may be included in Schedule B in accordance with the date commitment developed in discussions between SCE and the NRC staff.
As for the case of NRC-originated changes to Schedule A items, the NRC will provide SCE a reasonable opportunity to propose overall changes in the total ILS which would most effectively accommodate such issues.
Any resulting changes in schedules will thereupon be reflected in revised Schedules B and C submitted by SCE.
VII. MODIFICATIONS TO THE PLAN The licensee and the NRC recognize that the Plan itself may require future modifications. Accordingly, SCE will draft proposed modifications and submit a license amendment application for approval of the proposed changes. The changes will be made effective upon amendment issuance by NRC.
GEH:1475F