ML13323A889

Provides Justification for Util Corrective Actions Re Notice of Violation from 800310 Loss of Saltwater Cooling Incident. Proposed Hot Shutdown Time Limit Is Consistent W/Emergency Operating Instruction SO1-3-5.34

ML13323A889
Person / Time
Site:	San Onofre
Issue date:	12/26/1980
From:	Haynes J SOUTHERN CALIFORNIA EDISON CO.
To:	Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
80-09, 80-9, TAC-65149, NUDOCS 8101210232
Download: ML13323A889 (2)

Text

Southern California Edison Company P. 0. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD. CALIFORNIA 91770 J. G. HAYNES December 26, 1980 T ELEPHOMF MANAGER OF NUCLEAR OPERATIONS (213) 572-1742

~~7 Mr. R. H. Enaelken Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Region V Suite 202, Walnut Creek Plaza 1990 North California Boulevard Walnut Creek, California 94596

Dear Mr. Engelken:

DOCKET NO. 50-206 SAN ONOFRE - UNIT 1 Our letter of May 13, 1980, forwarded to you our Corrective Actions regarding a notice of violation concerning the March 10, 1980 loss of salt water cooling incident at San Onofre Nuclear Generating Station,.Unit 1.

Mr. Robert Pate, Resident Inspector, recently indicated that our May 13, 1980 response is inconsistent with the wording in Emergency Operating Instruction S01-3-5.34 as follows:.

Our response states:

Corrective Actions which have been Taken 1.a.( 2) Emphasis was placed on directing the operator to commence an immediate orderly shutdown of the unit in the event both the north and south salt water pumps are determined to be inoperable.

Emergency Operating Instruction States:

ImmediateOperator Action 3.1 If both the salt water cooling pumps become inoperable.

3.1.1 Unit shall be placed in at least hot shutdown within one (1) hour, and in at least cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> unless corrective measures are completed that permit operation.

01012102

Mr. R. H. Engelken

-2 We believe our response to your office in our May 13, 1980 letter and the implementation of that response in Emergency Operating Instruction S01-3-5.34 to be consistent for the following reason:

An "orderly shutdown" from full load requires approximately two hours. Thus, the requirement of S01-3-5.34 is more restrictive than our May 13 response to you.

Additionally, it is our understanding, based on a telephone conversation with Mr. Faulkenberry on April 9, 1980, that the region intended to use the Westinghouse Standard Technical Specifications as guidance in evaluating time constraints we specify in our emergency procedures. The time limit invoked in the Emergency Operating Instruction S01-3-5.34, "Loss of Salt Water to the Component Coolina System" is from the Westinghouse Standard Technical Specification.

It is not our intent, at anytime to prolong plant operations when such operations are outside a limiting condition for operation as specified in the Technical Specifications. We believe, however, that actions taken during emergency situations should proceed with thoughtfulness and due consideration for the conditions at hand.

For these reasons, we consider that the one hour time limit to be in hot shutdown is appropriate and consistent with our respnse to you in our May 13, 1980 letter.

We trust that this additional information clarifies our position on this matter, and we stand ready to further discuss the matter.

Very truly yours,