ML13310B634
| ML13310B634 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/16/1984 |
| From: | Medford M Southern California Edison Co |
| To: | Paulson W Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML13310B635 | List: |
| References | |
| TAC-54893, NUDOCS 8408210165 | |
| Download: ML13310B634 (4) | |
Text
Southern California Edison Company P. 0.
BOX 00 2244 WALNUT GROVE AVENUE ROSEMEAD. CALIFORNIA 91770 M.O. MEDFORD TELEPHONE MANAGER, NUCLEAR LICENSING August 16, 1984 (213) 572-1749 Director, Office of Nuclear Reactor Regulation Attention: W. A. Paulson, Acting Chief Operating Reactors Branch No. 5 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Gentlemen:
Subject:
Docket No. 50-206 Proposed Change Nos. 83, 125, 127, 130, and 136 San Onofre Nuclear Generating Station Unit 1
References:
- 1. Letter, Kenneth P. Baskin, SCE, to H. R. Denton, NRC, Amendment Application No. 117, May 1, 1984
- 2. Letter, Kenneth P. Baskin, SCE, to H. R. Denton, NRC, Amendment Application No. 121, July 9, 1984.
- 3. Letter, Kenneth P. Baskin, SCE, to H. R. Denton, NRC, Amendment Application No. 118, May 17, 1984.
- 4. Letter, Kenneth P. Baskin, SCE, to H. R. Denton, NRC, Amendment Application No. 120, June 8, 1984
- 5. Letter, M. 0. Medford, SCE, to D. M. Crutchfield, NRC, Radiological Effluent Technical Specifications, December 12, 1983 The References 1 through 4 transmitted Amendment Application Nos.
117, 118, 120, and 121 to Provisional Operating License No. DPR-13. Amendment Application Nos. 117, 118, 120, and 121 contained, among others, Proposed Change Nos. 125, 127, 130, and 136 to the Technical Specifications incorporated into Provisional Operating License No. DPR-13 as Appendices A and B. You also have Proposed Change No. 83, last revised by Reference 5, under review. In order to ensure consistency in the Technical Specifications, additional revisions to these proposed changes are necessary for reasons discussed below. Accordingly, the following information is provided.
The revisions to the Technical Specifications requested by Proposed Change No. 125 in Reference 2 concerned changes to the Limiting Conditions for Operation (LCO's) and Surveillance Requirements to existing Technical Specifications as well as adding new requirements required for post-TMI modifications installed or being installed during the current outage. The revisions inserted new portions to Section 3.0, "Limiting Conditions for MO8210165 840816 PDR ADOCK 05000206 p
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Mr. W. August 16, 1984 Operation (General)" and a new section 4.0, "Surveillance Requirements (General)."
The ACTION Statement numbering scheme was also revised from letters to numbers to be consistent with the Standard Technical Specifications (STS), to be consistent with Proposed Change No. 83 and to ensure that adequate numbers will be available for future revisions that require ACTION Statements. Section 3.1.1, "Maximum Reactor Coolant Activity" was revised to take exception to new Specification 3.0.4. However, our review has indicated that additional revisions are necessary to the reporting requirements portion of Specification 3.1.1.
These additional revisions, provided in Enclosure 2, are necessary to be consistent with the revisions of Proposed Change No. 130 and the new definitions of Proposed Change No. 125.
The revisions to the Technical Specifications requested by Proposed Change No. 127 in Reference 3 concerned the changes to the LCO's and Surveillance Requirements of the Auxiliary Feedwater System Instrumentation at San Onofre Unit 1. The revisions necessary are only a renumbering of the ACTION Statements in Specification 3.5.7, "Auxiliary Feedwater Instrumentation" for reasons that were previously discussed. The ACTION Statement numbers of Proposed Change No. 127 should be revised as follows:
Proposed Change No. 127 Old Number New Number T.S. 3.5.7 F
12 G
13 H
14 1
15 The revisions to the Technical Specifications requested by Proposed Change No. 130 in Reference 1 concern recent changes in the organizations responsible for the operation of San Onofre Unit 1, the recent rulemaking on reporting requirements, and other revisions necessary to provide consistency in administrative procedures among San Onofre Units 1, 2 and 3. The proposed change also renumbered certain portions of Appendix A, Section 6.0 to be consistent with the Standard Technical Specifications. Consequently, the references to Section 6.0 in the.remainder of the Appendix A Technical Specifications are, in some cases, incorrect. Our review of the remainder of the Appendix A Technical Specifications and Proposed Changes currently under your review has indicated additional changes necessary to-approve and issue the revised Technical Specifications in Proposed Change No..130 to the San Onofre Unit 1 Technical Specifications. These changes are.required in
Mr. W.
August 16, 1984 Specifications 3.1.1, "Maximum Reactor Coolant Activity," 3.1.4, "Leakage,"
4.2.3, "Safety Injection System Valve Testing," 4.8, "Reactivity Anomalies,"
4.12, "Miscellaneous Radioactive Materials Sources," and 4.16, "Inservice Inspection of Steam Generator Tubing."
Accordingly, the existing specifications are provided in Enclosure 1 and the revisions are provided in.
The revisions to the Technical Specifications requested by Proposed Change No. 136 in Reference 4 concerned changes to the San Onofre Unit 1 Fire Protection Systems LCO's and associated Surveillance Requirements. The new section 3.0.4 added in Proposed Change No. 125 must be referenced and taken exception to in the sections revised by Proposed Change No. 136 in order to ensure that continued plant operation is not impeded by the inoperability of equipment that does not affect plant safety and to provide consistency with the STS. Therefore, every reference to 3.O.A in the current submittal should be revised to read "3.0.3 and 3.0.4."
The revisions to the Technical Specifications requested by Proposed Change No. 83, currently under your review, concerned the changes to the LCO's and Surveillance Requirements as they apply to the radiological effluent measurement systems at San Onofre Unit 1. The revisions necessary are a renumbering of the ACTION Statements for reasons that were previously discussed. The ACTION Statement numbers should be revised as follows:
Proposed Change No. 83 Old Number New Number T.S.
3.5.8 1
16 2
17 3
18 4
19 T.S. 3.5.9 5
20 6
21 7
22 8
23 9
24 The revisions requested by this letter are administrative in nature, and are made to ensure consistency among all of the Technical Specifications.
Therefore, a special Amendment Application for the requested revisions to previously submitted proposed changes is not required.
Mr. W.
August 16, 1984 In addition, Amendment Application 121 requested a delay in the effective date of 30 days after issuance for Proposed Change No. 125.
Further review of the large number of procedures requiring revision and the required training time indicates that more than 30 days will be needed to fully implement the change. It is respectfully requested that the effective date be delayed until 60 days after issuance.
If you have any questions regarding the above discussed information, please let me know.
Very truly yours, Enclosure