ML13322B090
| ML13322B090 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/26/1990 |
| From: | Rosenblum R SOUTHERN CALIFORNIA EDISON CO. |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| GL-89-13, NUDOCS 9002090039 | |
| Download: ML13322B090 (4) | |
Text
Southern California Edison Company 23 PARKER STREET IRVINE, CALIFORNIA 92718 R.MROSENBLUM January 26, 1990 TELEPHONE MANAGER OF (714) 587-5420 NUCLEAR REGULATORY AFFAIRS U. S. Nuclear Regulatory Commission Attention:
Mr. J. B. Martin Regional Administrator, Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 Gentlemen:
Subject:
Docket Nos. 50-206, 50-361 and 50-362 Generic Letter No. 89-13: Service Water System Problems Affecting Safety-Related Equipment San Onofre Nuclear Generating Station Units 1, 2 and 3 This letter provides the Southern California Edison (SCE) initial response to Generic Letter (GL) 89-13 for San Onofre Nuclear Generating Station Units 1, 2 and 3. SCE is developing programs to implement recommended actions I through V of this Generic Letter and is providing the schedules of plans for implementation of the various actions below. The detailed documentation associated with GL 89-13, as requested, will be retained in appropriate plant records.
In the subject Generic Letter, the NRC requests that licensees perform specific actions to ensure that service water systems are in compliance and will be maintained in compliance with 10 CFR Part 50, Appendix A, General Design Criteria 44, 45 and 46 and Appendix B,Section XI.
The service water system is defined as the system or systems that transfer heat from safety related structures, systems or components to the ultimate heat sink. The scope of GL 89-13 includes intermediate systems used. between the safety related items and the system rejecting heat to the ultimate heat sink.
SCOPE Using the definition of open and closed-cycle systems provided in GL 89-13, SCE has determined that the following two systems are the only Unit 1, 2 and 3 open-cycle systems within the scope of recommended actions I, II and III:
Saltwater Cooling System - pumps, piping, valves and component cooling water heat exchangers (heat exchangers CCW-E-20A and B for Unit 1 and ME001 and ME002 for Units 2 and 3)
Intake Structure - Support for saltwater cooling system These two open-cycle cooling systems as well as the closed-cycle Component Cooling Water (CCW) system will be addressed in the SCE program responding to recommended actions IV and V.
90020900C39 9001:26 PDR ADOCK
'05000206 F'IPD p/o
J. January 26, 1990 The SCE approaches to recommended actions I through V are summarized as follows:
Recommended Action I SCE has implemented and maintains an ongoing surveillance and control program to reduce incidence of flow blockage associated with biofouling and other problems concerning the Salt Water Cooling (SWC) systems and intake structures. This program has been compared to the "Recommended Program to Resolve Generic Issue 51" (Enclosure 1 to the Generic Letter).
There are some differences between the San Onofre program and the NRC recommended program, however, the San Onofre program is an equally effective means of controlling marine growth and ensuring that the SWC system and intake structure will operate as required. Program procedures and documentation of the surveillances and controls performed are on file. The SWC systems remove heat from the CCW heat exchangers and discharge it to the Pacific Ocean.
Recommended Action II SCE will conduct a test program to verify the heat transfer capability of the CCW heat exchangers for all three units. This test program will be consistent with the "Program for Testing Heat Transfer Capability" (Enclosure 2 to the Generic Letter).
Recommended Action III SCE will establish a routine visual inspection and maintenance program for the two open-cycle systems identified above. The SCE program for the SWC system piping and components and for the intake structure will be to visually inspect representative sections of pipe and components made accessible by outage activities. Ultrasonic testing of SWC piping will be performed during non outage periods.
Recommended Action IV Safety-related open and closed-cycle service water cooling systems (SWC systems, intake structures and CCW systems) will be confirmed to perform their intended functions in accordance with the licensing basis for the plant.
Recommended Action V Maintenance practices, operating and emergency procedures, and training involving open and closed-cycle service water systems providing cooling for safety-related components will be confirmed to be adequate to ensure that this safety-related equipment will function as intended and that operators of this equipment will perform effectively. This confirmation will include recent (within the past two years) reviews of practices, procedures and training modules.
J. January 26, 1990 Additional Evaluations SCE believes GL 89-13 contains relevant guidance on our programs for several systems which appear to be outside the scope of this Generic Letter. The San Onofre emergency diesel generator coolers for Units 1, 2 and 3, the main feedwater pump lube oil coolers for Unit 1, and the charging pump lube oil coolers for Unit 1 are liquid-to-air heat exchangers (air-cooled radiators) which cool safety-related equipment but are not cooled by the service water system. The existing inspection and maintenance programs for these cooling systems will be evaluated to ensure that they will perform in accordance with the intent of recommended actions I through V of GL 89-13. This evaluation and, if necessary, changes to the current inspection and maintenance programs will be completed consistent with the schedules identified below for each Unit.
SCHEDULE As requested in GL 89-13: 1) Test and inspection plans will be available prior to the first refueling outage for each unit beginning 9 months after the July 18, 1989 date of this generic letter, 2) Initial activities for recommended actions I and II will be completed before plant startup following these refueling outages, and 3) Recommended actions III, IV and V will be completed before plant startup following these refueling outages. The schedules for each unit are as follows:
GENERIC LETTER 89-13 IMPLEMENTATION SCHEDULE SCHEDULED REFUELING OUTAGE
- ITEM Unit 1 Unit 2 Unit 3 Test and Inspection Plans Cycle 11 Cycle 6 Cycle 6 (Complete prior to outage)
Recommended Actions I and II Cycle 11 Cycle 6 Cycle 6 Initial Activities and Tests (Complete prior to end of outage)
Recommended Actions III, IV and V Cycle 11 Cycle 6 Cycle 6 (Complete prior to end of outage)
The currently scheduled start and end dates (subject to change) for the first refueling outages beginning 9 months after the date of GL 89-13 are the following:
Refueling Outage Start End Unit 1 Cycle 11 6/30/90 12/90 Unit 2 Cycle 6 7/91 9/91 Unit 3 Cycle 6 1/92 4/92
J. B. Martin 4 -
January 26, 1990 As further requested in GL 89-13, SCE commits to providing a single written confirmation to the NRC (within 30 days of implementation) that the following actions or justified alternatives have been implemented for each unit:
- 1) All initial activities and tests for recommended actions I and II, and
- 2) Recommended actions III, IV and V, and
- 3) Establishment of continuing programs for recommended actions I and II.
Based on the above commitments and descriptions, the GL 89-13 recommended actions will be met directly or by equivalent measures and the GL 89-13 schedules will be met for San Onofre Units 1, 2 and 3.
If you would like additional information concerning this matter, please let me know.
Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY By:
R. M. Rosenblum Manager of Nuclear Regulatory Affairs Subscribed and sworn to before me this 026 /1 day of lO///AA
/99.
U OFFICIAL SEAL MIC-'HELE R. KAHAL PR NC PAL OF:FICE IN ORANCE COUNTY My Comlmiion1 ExP. Dec 28, 1990 Notary Public in the State of California cc:
Document Control Desk, USNRC, Washington D.C. 20555 (Original)
C. Caldwell, NRC Senior Resident Inspector, San Onofre Units 1, 2 and 3