ML13330A203
| ML13330A203 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/04/1981 |
| From: | Baskin K Southern California Edison Co |
| To: | Crutchfield D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8102100022 | |
| Download: ML13330A203 (5) | |
Text
an -Z:Southern California Edison Company P. 0. BOX 800 oD 2244WALNUTGROVEAVENUE u
CO ROSEMEAD. CALIFORNIA 91770 K P. BASKI February 4, 1981 TELEPHONE MANAGER.OF NUCLEAR-ENG INEER NG, (213) 572-1401 SA' TY, AND LI NSING Director 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 0 6199 1 Gentlemen:
Subject:
Docket No. 50-206 Systematic Evaluation Program San Onofre Nuclear Generating Station Unit 1 SCE has reviewed your letter of January 14, 1981, which was telecopied to us on February 2, 1981.
We concur that the majority of the commitments specified were agreed to in meetings among the SEP Owners with representatives of the NRC SEP staff. Specifically, the SEP Owners Group program provides that:
(1) 60% of the topic assessments are to be completed by the end of June, 1981 and (2) for each SEP topic whose review has not begun there be a lead plant identified to actively support the NRC staff reviewers in their development of an initial draft topic assessment for each topic.
In accordance with our discussions with the NRC staff, there will be a 90 day trial period for this redirected program. At the end of this period an assessment of this approach will be made.
The nine SEP Owners Group plants represent a total of 1233 SEP topics to be resolved.
As of January 9, 1981, 504 of those topics were identified as deferred from the SEP as a generic issue or were not applicable to SEP. In addition, 207 topics had draft or final SER's issued. The SEP Owners Group members will review the completed SER's and apply the criteria and findings where possible in generating assessments of the topic for other plants. Where no SER is yet complete, the designated plant for that particular topic will cooperate with the NRC staff in developing a final SER, which will include the review criteria based on specific regulations, NRC Regulatory Guides or Standard Review Plans as well as acceptable alternatives. The resulting SERs will also be used by others to generate draft assessments for these topics.
It is anticipated that draft SER's issued by the NRC by January 15, 1981 will be reviewed and returned to the staff for finalization by the end of February, 1981.
Draft SER's issued by the NRC subsequent to January 15, 1981 will be reviewed and responded to within 30 days from date of receipt.
8Io 1Sa0a
D.
February 4, 1981 In order for these goals to be realized by the staff and the SEP Owners Group, the staff's resources are expected to be concentrated toward prompt issuance of draft SER's and toward review of the licensee topic assessment submittals and SER responses. In cases where the staff has employed consultants to perform certain evaluations, particularly electrical, instrumentation and control evaluations, it would be expedient for the consultants to complete the development of draft SER's on those topics for each of the plants, rather than have the consultants review licensee prepared topic assessments and then generate SERs.
In response to the conditions specified in your January 14, 1981 letter:
- 1.
SCE agrees to complete SEP topic assessments for topics whose review has not yet begun such that a 60% aggregate total of assessments have been completed or submitted for review by June 30, 1981.
SCE has identified a list of candidate topics from which it is anticipated that this 60% can be accomplished for San Onofre Unit 1 when taken in conjunction with the generic or deleted topics.
This list is provided as an enclosure to this letter.
- 2.
SCE commits to actively support the NRC staff in their development of an initial draft topic assessment for each topic for which San Onofre has been designated as having the lead. However it should be recognized that some of the long-lead or criteria deficient topics may preclude that accomplishment. The topics for which San Onofre Unit 1 has been designated as having the lead are identified in the enclosure.
- 3.
SCE as a member of the SEP Owners Group agrees to the 90 day trial period.
- 4.
SCE considers that NRC Staff resources should be expended to work with the SEP Owners Group to effect the lead topic approach.
Additional efforts being completed on the Palisades plant as part of the "Lead Plant" concept should not interfere with this approach.
- 5. SCE cannot commit at this time to assigning a local representative in Bethesda as part of the SEP.
- 6. SCE agrees that the SEP Owners Group should meet periodically (bi-monthly) with NRC SEP management to discuss SEP progress and program planning.
- 7. SCE agrees to respond to draft SER's and advise the NRC staff of findings within the 30 day response period.
SCE and the SEP Owners Group appreciate the staff's adoption of the Owners Group plan to implement resolution of SEP topics preparatory to the development of the integrated assessment for each plant. It is anticipated that the commitments specified above satisfy the staff requirements for
D.
February 4, 1981 orderly resolution of the SEP. However, SCE and the SEP Owners Group are concerned that SECY-81-13 as discussed during a Commissioner's briefing on January 14, 1981, and made publicly available that same date, may preclude the orderly completion of the SEP as presently constituted. SECY-81-13 appears to state that the present SEP addresses Section 110 of Public Law 960295 because the topics were obtained from an engineering approach which reviewed at least 1100 issues to determine those issues of greater potential safety significance. The 137 issues chosen from the list are those deemed to have the greatest potential for safety significance and therefore, address Section 110 requirements to review particularly significant safety requirements. The reason the SEP approach is not being used to satisfy the requirement of Section 110 of Public Law 960295 for the remaining operating units is that the industry and not the staff will be required to perform the review. If this understanding of SECY-81-13 is incorrect and new requirements are imposed upon SEP as a result of the implementation of SECY-81-13, SCE considers that total re-evaluation of the SEP and its scheduled completion will be required.
Very truly yours, Enclosure
List of Candidate SEP Topics For Completion by June, 1981 San Onofre Unit 1 II-1.A Exclusion Area Authority and Control II-1.B Population Distribution II-2.A Severe Weather Phenomena II-2.C Atmospheric Transport and Diffusion Characteristics for Accident Analysis II-3.A Hydrologic Description II-3.B Flooding Potential and Protection Requirements II-3.B.1 Capability of Operating Plants to Cope with Design Basis Flooding Conditions III-3.A Effects of High Water Level on Structures III-3.C Inservice Inspection of Water Control Structures (Designated Lead Topic for San Onofre)
III-4.B Turbine Missiles (Designated Lead Topic for San Onofre)
III-7.D Containment Structural Integrity Tests III-8.C Irradiation Damage, Use of Sensitized Stainless Steel and Fatigue Resistance III-10.A Thermal-Overload Protection for Motors of Motor-Operated Valves III-10.B Pump Flywheel Integrity (Designated Lead Topic for San Onofre)
IV-1.A Operation With Less Than All Loops In Service V-5 Reactor Coolant Pressure Boundary (RCPB) Leakage Detection V-6 Reactor Vessel Integrity V-10.A Residual Heat Removal System Heat Exchanger Tube Failures V-1O.B Residual Heat Removal System Reliability V-11.A Requirements for Isolation of High and Low Pressure Systems V-11.B RHR Interlock Requirements
-2 VI-2.D Mass and Energy Release for Postulated Pipe Breaks Inside Containment (Designated Lead Topic for San Onofre)
VI-3 Containment Pressure and Heat Removal Capability (Designated Lead Topic for San Onofre)
VI-7.A.1 ECCS Re-evaluation to Account for Increased Reactor Vessel Upper Head Temperature VI-7.B ESF Switchover From Injection to Recirculation Mode (Automatic ECCS Realignment) (Designated Lead Topic for San Onofre)
VI-7.C.1 Appendix K - Electrical Instrumentation and Control (EIC) Re-reviews VI-10.B Shared Engineered Safety Features Onsite Emergency Power, and Service Sytems for Multiple Unit Stations VII-3 Systems Required for Safe Shutdown VIII-2 Onsite Emergency Power Systems - Diesel Generator VIII-3.A Station Battery Capacity Test Requirements VIII-3.B DC Power System Bus Voltage Monitoring and Annunciation IX-1 Fuel Storage (Designated Lead Topic for San Onofre)
IX-3 Station Service and Cooling Water Systems XV-2 Spectrum of Steam System Piping Failures Inside and Outside of Containment (PWR) (Designated Lead Topic for San Onofre)
XV-20 Radiological Consequences of Fuel Damaging Accidents (Inside and Outside Containment)