ML13331A815

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Requests Delay in Implementation of Proposed Change 130 to Tech Specs,Revising Time Period for Submittal of Semiannual Radioactive Effluent Release Rept from 60 to 90 Days.Revised Tech Specs Encl
ML13331A815
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 07/01/1985
From: Medford M
SOUTHERN CALIFORNIA EDISON CO.
To: Zwolinski J
Office of Nuclear Reactor Regulation
Shared Package
ML13331A817 List:
References
TAC-54893, NUDOCS 8507030335
Download: ML13331A815 (3)


Text

REGULATORY I)RMATION DISTRIBUTION SYST 0 (RIDS)

ACCESSION NBR:8S07030335 DOC.DATE: 85/07/01 NOTARIZED: NO DOCKET #

FACIL:50-206 San Onofre Nuclear Station, Unit 1, Southern Californ 05000206 AUTH.NAME AUTHOR AFFILIATION MEDFORDM,0, Southern California Edison Co.

RECIP.NAME RECIPIENT AFFILIATION ZWOLINSKIJ,A, Operating Reactors Branch 5

SUBJECT:

Requests delay in implementation of Proposed Change 130 to Tech Specsorevising time period for submittal of semiannual radioactive effluent release rept from 60 to 90 daysRevised Tech Specs encl.

DISTRIBUTION CODE: AO01D COPIES RECEIyED:LTR -1 ENCL.-

SIZE:_.

TITLE: OR Submittal: General Distribution NOTES:NRR/DL/SEP icy, 05000206 OL:03/27/67 RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAMEi LTTR ENCL, ID CODE/NAME LTTR ENCL NRR ORBS BC 01 7

7 INTERNAL: ACRS 09 6

6 ADM/LFMB 1

0 ELD/HDS2 1

0 NRR/DE/MTEB 1

1 NRR/DL DIR 1

1 NRR/DL/ORAB 1

0 NRR/DL/TSRG 1

1 NFM/

METB 1

1 NRR/DSI/RAB 1

1 02EG F ILE 04 1

1 RGNS 1

1 EXTERNAL: 24X 1

1 EG&G BRUSKES 1

1 LPDR 03:

1 1

NRC PDR 02 1

11 NSIC 05 1

1 NOTES:

1 1

TOTAL NUMBER OF COPIES REQUIRED: LTTR 29 ENCL 26

Southern California Edison Company P. 0. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD. CALIFORNIA 91770 M. 0. MEDFORD TELEPHONE MANAGER, NUCLEAR LICENSING July 1, 1985 (818) 302 1749 Director, Office of Nuclear Reactor Regulation Attention:

Mr. 3. A. Zwolinski, Chief Operating Reactors Branch No. 5 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C.

20555 Gentlemen:

Subject:

Docket No. 50-206 Administrative Technical Specifications San Onofre Nuclear Generating Station Unit 1

Reference:

Letter, M.O. Medford, SCE, to 3. A. Zwolinski, NRC, Proposed Changes to Section 6.0, Administrative Controls, April 12, 1985 The referenced letter provided you with a revision to our Proposed Change No. 130 that incorporated changes discussed at a meeting with the NRC staff and subsequent telephone discussions. In response to recent discussions with the NRC staff regarding some additional inconsistencies in the proposed change, the following discussion and enclosed revised pages are provided.

The revised proposed change provided with the referenced letter revised the time period for submittal of the Semi-Annual Radioactive Effluent Release Report from 60 days to 90 days in order to allow additional time to prepare the report. The staff noted that the 60 days is required by 10 CFR 50.36a.2 and cannot be revised without good cause. Since this revision was proposed only for our convenience to provide extra time for preparation of the report this proposed revision is withdrawn and the appropriate change is reflected in the enclosure to this letter.

The revised proposed change provided with the referenced letter indicated in Section 14 "Offsite Dose Calculation Manual (ODCM)," that changes to the ODCM would be included in the monthly operating report 90 days following the date the change was made effective. This revision was proposed to be consistent with the submittal requirements of San Onofre Units 2 and 3.

Discussions with the staff indicated that their contract to have the ODCM changes reviewed is structured to receive them semi-annually and any change to our submittal schedule would be inconsistent with that schedule. However, the staff did acknowledge the need for San Onofre Unit 1, and Units 2 & 3 to be consistent, since the changes to the ODCM concern all three units. Based upon E070303 3 5 850701 PDR FD DC(0000

Mr. J.

July 1, 1985 our re-examination of our method of developing ODCM changes, we have revised the submittal schedule to be semi-annually and this revision is reflected in the page changes enclosed with this letter. Any changes to San Onofre Units 2 and 3 to assure consistency will be made in a separate letter.

Based on recent discussions with the NRC staff on the incorporation of the new Licensee Event Report (LER) requirements into the non-Section 6.0 Technical Specifications, the revision to the text of specification 3.18.1.B.3 is not appropriate and we withdraw this proposed revision at this time.

However, it is noted that a revision to specification 3.18.1.B.3 and other specifications will be required in the future. These changes will be the subject of a future proposed change. Based upon the previous discussion, the text of specification 3.18.1.B.3 as shown in the enclosure is appropriate.

In order to allow the transition of the procedures and administrative programs at San Onofre Unit 1 that will be affected by the changes of Proposed Change No. 130, a delay in the implementation of the amendment is respectfully requested. The method used for the issuance of Amendment No. 83, which stated that the amendment was effective the date of issuance and shall be implemented within 30 days, is requested.

If you have any questions, please let me know.

Very truly yours, LB:4371F Enclosures cc:

J. B. Martin, Regional Administrator, Region V F. R. Huey, USNRC Senior Resident Inspector, San Onofre Units 1, 2 and 3 J. 0. Ward, California Department of Health Services bcc: (See attached sheet)