ML13317A616

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Advises That TMI Action Plan Item II.K.3.9 Was Not Completed by 810101.Facility Has Been Shut Down Since Apr 1980.Item Will Be Completed Prior to Restart.Also Lists Completion Schedules for Items II.D.3,II.E.4.2.,II.G.1 & III.D.3.3
ML13317A616
Person / Time
Site: San Onofre 
Issue date: 05/12/1981
From: Baskin K
Southern California Edison Co
To: Crutchfield D
Office of Nuclear Reactor Regulation
References
TAC-44128, TASK-2.D.3, TASK-2.E.4.2, TASK-2.G.1, TASK-2.K.3.09, TASK-3.D.3.3, TASK-TM NUDOCS 8105180322
Download: ML13317A616 (3)


Text

00 Southern California Edison Company P. 0. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD. CALIFORNIA 91770 K. P. BASKIN MANAGER OF NUCLEAR ENGINEERING, May 12, 1981 SAFETY, AND LICENSING Director, Office of Nuclear Reactor Regulation 1, MAY1 Attention: D. M. Crutchfield, Chief Operating Reactors Branch No. 5 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:

Subject:

Docket No. 50-206 Implementaton of TMI Action Plan Requirements San Onofre Nuclear Generating Station Unit 1 During an NRC regional inspection exit interview on March 24, 1981, the Regional Inspectors indicated that they had determined that TMI Action Plan Item II.K.3.9, Proportional Integral Derivative Controller Modification, had not been initiated. The modification involves setting the derivative time constant in the proportional integral derivative controller for the pressurizer power operated relief valves (PORV's) to off; and in effect, remove the derivative action from the controller which decreases the likelihood of opening the PORV's since the actuation signal for PORV's is then no longer sensitive to the rate of change of pressurizer pressure. Our June 13, 1980 letter indicated that the modification would be completed by July 1, 1980 as set forth in your May 7, 1980 letter. The implementation date for this modification was later changed to January 1, 1981 by your October 31, 1980 letter. During the exit interview, it was agreed by everyone that since San Onofre Unit 1 is currently shut down, the completion dates were intended to mean "prior to return to power."

However, the Regional Inspectors stated that the NRC should have been notified about the rescheduled completion dates, and we agreed to notify the NRC.

During subsequent discussions with one of the Regional Inspectors, representatives of my Nuclear Licensing Organization indicated that the implementation of approved TMI-related items have been explicitly characterized as follows:

1. implementation by a specified date,
2. implementation by a specified date, or the Station shutdown on that specified date until completion, or
3.

implementation prior to return to power from the current outage.

8105180

D.

May 12, 1981 In addition, we indicated that approved TMI-related items characterized in Item 1 above are considered the same as those characterized in Item 2 above. Furthermore, we indicated that we interpret the implementation dates for approved TMI-related items to require that the items be completed by the specified date or the station shutdown until completion of the items, unless otherwise authorized by the NRC and that a separate letter has not been required by the NRC in the past notifying them that an item has not been completed by the specified date, that the station has been shutdown to complete the item and that the item will be completed prior to return to power from the shutdown. The Regional Inspector did not disagree with this interpretation; however, he still requested that we notify the NRC to clarify this issue.

Accordingly, the purpose of this letter is to advise you that TMI Action Plan Item II.K.3.9 was not completed by January 1, 1981 as specified in your October 31, 1980 letter and characterized in Item 1 above. However, San Onofre Unit 1 has remained shutdown since April, 1980, and we will complete this item prior to return to power following the current shutdown. As discussed with the Regional Inspector, other TMI Action Plan Items which were not completed by the specified implementation dates during the current shutdown and characterized in Item 1 above include:

Action Plan Item II.D.3-Direct Indication of Relief-and Safety-Valve Position By letter dated January 1, 1980, we indicated that "controls grade" equipment would be utilized to the extent necessary to comply with this item during the special TMI outage in January-February, 1980.

We also indicated that any non-conforming equipment utilized would be qualified or replaced by January 1, 1981.

The qualification or replacement of non-conforming equipment is scheduled to be completed prior to return to power from the current shutdown.

Action Plan Item II.E.4.2(6)-Procedures for Verifying that Purge and Vent Valves are Closed During Operation By letter dated January 5, 1981, we indicated our plans to comply with this item. Accordingly, the procedures are scheduled to be developed and implemented prior to return to power from the current shutdown.

Action Plan Item II.G.1-Emergency Power for Pressurizer Equipment By letter dated January 1, 1980, we indicated that "controls grade" equipment would be utilized to the extent necessary to provide a backup nitrogen pneumatic supply to the PORV block valves to ensure the functioning of the valves following loss of station instrument air during the special TMI outage in January-February, 1980.

We also indicated that any non-conforming equipment utilized would be qualified or replaced by January 1, 1981. The qualification or replacement of non-conforming equipment is scheduled to be completed prior to return to power from the current shutdown.

D.

May 12, 1981 Action Plan Item III.D.3.3-Training and Procedures for Use of Portable Battery Powered Air Samplers and Cart Mounted A.C. Powered Air Samplers to Determine Airborne Iodine Concentration By letter dated January 1, 1980, we described existing equipment to detemine airborne iodine concentration and indicated that training and procedures for use of this equipment would be developed and implemented prior to return to power from the special TMI outage in January-February, 1980.

We also indicated that new portable battery powered air samplers and cart mounted A.C.

powered air samplers with built-in single channel analyzers would be delivered in February, 1980 and mid-1980, respectively, in order to provide additional flexibility in determining the airborne iodine concentration, and that training and procedures for use of these air samplers would be developed and implemented within thirty days of receipt of the air samplers. The portable battery powered air samplers were received in December, 1980 and the cart mounted A.C. powered air samplers were received in February, 1981.

The training and procedures for use of the air samplers will be developed and implemented prior to return to power from the current shutdown.

Based on our review of TMI Action Plan Items currently being implemented, these are the only items subject to our interpretation and requiring clarification in accordance with the Regional Inspector's request.

If you do not agree with our interpretation as discussed above, and you desire to be notified by letter when similar situations occur in the future, please contact me.

Very truly yours, cc:

R. H. Engelken, Director, OIE, Region V L. F. Miller, Resident Inspector