ML13330A177
"Draft Meeting" is not in the list (Request, Draft Request, Supplement, Acceptance Review, Meeting, Withholding Request, Withholding Request Acceptance, RAI, Draft RAI, Draft Response to RAI, ...) of allowed values for the "Project stage" property.
| ML13330A177 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 01/12/1981 |
| From: | Baskin K Southern California Edison Co |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML13316B813 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TAC-65149 NUDOCS 8101130544 | |
| Download: ML13330A177 (6) | |
Text
Southern California Edison Company P. 0. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 K. P. BASKIN January 12, 1981 TELEPHONE MANAGER OF NUCLEAR ENGINEERING, (213) 572-1401 SAFETY, AND LICENSING Director, Office of Nuclear Reactor Regulation 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 Saltwater'Cooling System San Onofre Nuclear Generating Station Unit 1 During a meeting held in Bethesda, Maryland on December 23, 1980, we met with members of the Regulatory staff to review the report entitled, "Draft Report on the San Onofre Unit 1 Loss of Saltwater Cooling on March 10, 1980,"
which was received on December 11, 1980. The report was prepared by the Office for Analysis and Evaluation of Operational Data (AEOD) to document the results of studies completed to date by them with regard to the event. The Office for AEOD evaluated and analyzed the event by reviewing inspection reports, operating and maintenance logs and specific information submitted in response to NRC inquiries and by directly interviewing Southern California Edison Company personnel familiar with the event.
The review of the report consisted of a detailed discussion of our comments on the findings and recommendations contained therein. A marked-up copy of the report identifying our comments was provided to the Regulatory staff present at the meeting. In order to summarize our comments for the purpose of this letter, we have compiled similar comments made throughout the report to form the following general comments:
- 1.
The finding that "controls over the plant's maintenance activities represents a serious breakdown of management controls over the maintenance program" appears to be an unwarranted broad generalization to the overall maintenance program based on a review of information limited to one event. In addition, the Performance Appraisal Inspection, the Systematic Assessment of Licensee Performance and the Office of Inspection and Enforcement, Region V, who is charged with the responsibility to audit the effectiveness of the maintenance program, have never come to this conclusion.
D. M. Crutchfield, Chief
-2
- 2.
A discussion of the history of the technical specification governing the Limiting Conditions for Operation of the Saltwater Cooling System, including the saltwater cooling pumps and the auxiliary saltwater cooling pump, prior to the event should be included in order to provide the proper perspective on the decisions made and the actions taken during the event.
- 3.
The increasing temperature of the thrust bearing on the south charging pump and the subsequent need to remove the pump from service and replace the bearing after the event should not be attributed to the failure of the Saltwater Cooling System. The thrust bearing temperature was being monitored and was rising prior to the event and the pump was removed from service and the bearing replaced when the temperature exceeded the manufacturer's recommended operating limit.
- 4.
The use of adjectives such as excessive, rapidly, immediately, and apparently to amplify the author's understanding or perception of the event are overstatements and place an unwarranted emphasis/significance on the information being presented.
- 5.
The recommendations are currently being pursued as part of interactions with the NRC, associated with the Performance Appraisal Inspection, Systematic Evaluation Program and Decay Heat Removal Technical Specifications. The recommendations duplicate those previously made by the NRC, except that a more restrictive schedule is sought.
In addition to the above comments, the Regulatory staff requested certain additional information during the December 23, 1980 meeting, which they indicated was necessary to complete the report. The requested information was informally provided to the Regulatory staff on January 6, 1981, and is submitted herewith as Enclosures 1, 2 and 3 of this letter as follows:
- 1. :
Entries transcribed from operator logs for 1978, 1979 and 1980 delineating corrective actions which have been taken associated with the instrument air system (actual copies of the operator logs were provided to the Regulatory staff on December 6, 1980).
- 2. :
A copy of WCAP-2889, Primary Plant Manual, Volume I, Precautions, Limitations and Set Points, January, 1966, which provides (page P-3:5) the recommended set point for charging pump sleeve bearings as 180OF (the actual set point is 175 0F and there is no alarm for charging pump thrust or motor bearings).
- 3. : A copy of the training material and representatives who attended the training sessions following the event.
D. M. Crutchfield, Chief
-3 Subsequent to the December 23, 1980 meeting, the Regulatory staff requested that we provide our interpretation of the technical specification governing the Limiting Conditions for Operation of the Saltwater Cooling System, including the saltwater cooling pumps and auxiliary saltwater cooling pump, prior to the event. We informally provided our interpretation to the Regulatory staff on January 6, 1981, which is submitted herewith as of this letter.
As has been discussed with the Regulatory staff, our further review of the report subsequent to the December 23, 1980 meeting revealed that incorrect design information had been provided concerning the flowrate of the auxiliary saltwater cooling pump. Based on the manufacturer's (Ingersoll-Rand) pump head-flow curves, the auxiliary saltwater cooling pump is rated at 4620 gpm and not the 1500 gpm previously provided to the Regulatory staff. -The actual capacity of the auxiliary saltwater cooling pump is equivalent to the saltwater cooling pumps and the discussion presented in this report comparing the design capacity of these pumps should be revised to reflect the new information. The manufacturer's pump head-flow curves were informally provided to the Regulatory staff on January 6, 1981 and are submitted herewith as Enclosure 5 of this letter.
At the conclusion of the December 23, 1980 meeting, the Regulatory staff indicated that our comments would be considered prior to finalizing the report.
Considering that the report, when finalized, will be released to the Offices of Nuclear Reactor Regulation and Inspection and Enforcement for followup actions, if deemed appropriate by those Offices, and a summary overview of the findings and recommendations will be included in the NRC's quarterly report to Congress as a significant safety issue, it is respectfully requested that we be given an opportunity to discuss the resolution of our comments with the Regulatory staff prior to the publication of the report.
If you have any questions,or desire further information concerning the enclosed material or our request to review the report prior to issuance, please contact me.
Very truly yours, Enclosures (5) cc:
C. Michelson, Director Office for AEOD (w/o enclosures)
R. H. Engelken, Director, OIE, Region (w/o enclosures)
Ke 0
Southern California Edison Company P. 0. BOX 200 2244 WALNUT GROVE AVENUE ROSEMEAD. CALIFORNIA 91770 K. P. BASKIN January 12, 1981TELEPONE MANAGER OF NUCLEAR ENGINEERING, (213) 572-1401 SAFETY. AND LICENSING Director, Office of Nuclear Reactor Regulation 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 Saltwater Cooling System San Onofre Nuclear Generating Station Unit 1 During a meeting held in Bethesda, Maryland on December 23, 1980, we met with members of the Regulatory staff to review the report entitled, "Draft Report on the San Onofre Unit 1 Loss of Saltwater Cooling on March 10, 1980,"
which was received on December 11, 1980. The report was prepared by the Office for Analysis and Evaluation of Operational Data (AEO0) to document the results of studies completed to date by them with regard to the event. The Office for AEOD evaluated and analyzed the event by reviewing inspection reports, operating and maintenance logs and specific information submitted in response to NRC inquiries and by directly interviewing Southern California Edison Company personnel familiar with the event.
The review of the report consisted of a detailed discussion of our comments on the findings and recommendations contained therein. A marked-up copy of the report identifying our comments was provided to the Regulatory staff present at the meeting. In order to summarize our comments for the purpose of this letter, we have compiled similar comments made throughout the report to form the following general comments:
- 1.
The finding that "controls over the plant's maintenance activities represents a serious breakdown of management controls over the maintenance program" appears to be an unwarranted broad generalization to the overall maintenance program based on a review of information limited to one event. In addition, the Performance Appraisal Inspection, the Systematic Assessment of Licensee Performance and the Office of Inspection and Enforcement, Region V, who is charged with the responsibility to audit the effectiveness of the maintenance program, have never come to this conclusion.
- 0. M. Crutchfield, Chief
-2
- 2.
A discussion of the history of the technical specification governing the Limiting Conditions for Operation of the Saltwater Cooling System, including the saltwater cooling pumps and the auxiliary saltwater cooling pump, prior to the event should be included in order to provide the proper perspective on the decisions made and the actions taken during the event.
- 3.
The increasing temperature of the thrust bearing on the south charging pump and the subsequent need to remove the pump from service and replace the bearing after the event should not be attributed to the failure of the Saltwater Cooling System. The thrust bearing temperature was being monitored and was rising prior to the event and the pump was removed from service and the bearing replaced when the temperature exceeded the manufacturer's recommended operating limit.
- 4.
The use of adjectives such as excessive, rapidly, immediately, and apparently to amplify the author's understanding or perception of the event are overstatements and place an unwarranted emphasis/significance on the information being presented.
- 5.
The recommendations are currently being pursued as part of interactions with the NRC, associated with the Performance Appraisal Inspection, Systematic Evaluation Program and Decay Heat Removal Technical Specifications. The recommendations duplicate those previously made by the NRC, except that a more restrictive schedule is sought.
In addition to the above comments, the Regulatory staff requested certain additional information during the December 23, 1980 meeting, which they indicated was necessary to complete the report. The requested information was informally provided to the Regulatory staff on January 6, 1981, and is submitted herewith as Enclosures 1, 2 and 3 of this letter as follows:
- 1. :
Entries transcribed from operator logs for 1978, 1979 and 1980 delineating corrective actions which have been taken associated with the instrument air system (actual copies of the operator logs were provided to the Regulatory staff on December 6, 1980).
- 2. :
A copy of WCAP-2889, Primary Plant Manual, Volume I, Precautions, Limitations and Set Points, January, 1966, which provides (page P-3:5) the recommended set point for charging pump sleeve bearings as 180OF (the actual set point is 1750F and there is no alarm for charging pump thrust or motor bearings).
- 3. :
A copy of the training material and representatives who attended the training sessions following the event.
D. M. Crutchfield, Chief
-3 Subsequent to the December 23, 1980 meeting, the Regulatory staff requested that we provide our interpretation of the technical specification governing the Limiting Conditions for Operation of the Saltwater Cooling System, including the saltwater cooling pumps and auxiliary saltwater cooling pump, prior to the event.
We informally provided our interpretation to the Regulatory staff on January 6, 1981, which is submitted herewith as of this letter.
As has been discussed with the Regulatory staff, our further review of the report subsequent to the December 23, 1980 meeting revealed that incorrect design information had been provided concerning the flowrate of the auxiliary saltwater cooling pump. Based on the manufacturer's (Ingersoll-Rand) pump head-flow curves, the auxiliary saltwater cooling pump is rated at 4620 gpm and not the 1500 gpm previously provided to the Regulatory staff. The actual capacity of the auxiliary saltwater cooling pump is equivalent to the saltwater cooling pumps and the discussion presented in this report comparing the design capacity of these pumps should be revised to reflect the new information. The manufacturer's pump head-flow curves were informally provided to the Regulatory staff on January 6, 1981 and are submitted herewith as Enclosure 5 of this letter.
At the conclusion of the December 23, 1980 meeting, the Regulatory staff indicated that our comments would be considered prior to finalizing the report. Considering that the report, when finalized, will be released to the Offices of Nuclear Reactor Regulation and Inspection and Enforcement for followup actions, if deemed appropriate by those Offices, and a summary overview of the findings and recommendations will be included in the NRC's quarterly report to Congress as a significant safety issue, it is respectfully requested that we be given an opportunity to discuss the resolution of our comments with the Regulatory staff prior to the publication of the report.
If you have any questions or desire further information concerning the enclosed material or our request to review the report prior to issuance, please contact me.
Very truly yours, Enclosures (5) cc:
C. Michelson, Director Office for AEOD (w/o enclosures)
R. H. Engelken, Director, OIE, Region (w/o enclosures)