ML13331B217
| ML13331B217 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/01/1989 |
| From: | Ray H SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML13331B218 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.2, TASK-TM GL-82-28, NUDOCS 8911080027 | |
| Download: ML13331B217 (2) | |
Text
Southern Califomia Edison Company 23 PARKER STREET IRVINE. CALIFORNIA 92718 HAROLD B.
RAY TELEPHONE VICE PRESIDENT 714 458-4400 November 1, 1989 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Docket No. 50-206 Amendment Application No. 174 San Onofre Nuclear Generating Station Unit 1 Enclosed is Amendment Application No. 174 to Provisional Operating License DPR-13. This application consists of Proposed Change No. 215 which is a request to revise License Condition 3.N to allow deferral of the implementation of outstanding requirements for the Inadequate Core Cooling (ICC) Instrumentation System from Fuel Cycle 11 to Fuel Cycle 12.
his deferral is being requested because the Cycle 11 refueling schedule s recently been revised, and it will now occur in mid-1990.which is more an 1 year sooner than previously anticipated. This earlier Cycle 11 refueling date does not provide sufficient time to complete required engineering, testing and procurement activity to support installation of the complete ICC Instrumentation System prior to commencing Cycle 11 operation.
BACKGROUND In a letter dated May 10, 1989, the NRC ordered that San Onofre Unit 1 be modified to implement all of the requirements of NUREG-0737, Item II.F.2, "Inadequate Core Cooling Instrumentation System" (Generic Letter 82-28),
not later than the startup for Fuel Cycle 11.
This requires installation of a Reactor Vessel Level Monitoring System (RVLMS) and upgrade of the Core Exit Thermocouples (CETs).
As discussed in my letter dated October 2, 1989, Edison has concluded that the Cycle 11 refueling should occur at the time of an extended outage to repair the thermal shield. This outage must commence not later than June 30, 1990. As shown in Figure 3 of that letter, this is more than one year prior to when the Cycle 11 refueling would otherwise occur in late 1991.
DISCUSSION e RVLMS installation for San -Onofre Unit 1 will be a unique design. As iscussed in the enclosure, Edison is proceeding with required engineering, testing and procurement activities, however they cannot be completed in time to install' RVLMS during the rescheduled Cycle 11 refueling, as currently required by License Condition 3.N.
89y(11)80027 851101 PDR ADOCK 05000206 P.
cument Control Desk November 1, 1989 Accordingly, Proposed Change No. 215 requests that the license condition be revised to refer to the Cycle 12 refueling instead and that the date for submittal of specific implementation plans be delayed. In addition, the change requests delay in upgrade of existing core exit thermocouples in order to obtain design and ALARA benefits from combining this work with installation of the RVLMS.
Without revision of License Condition 3.N, Edison will not be able to conduct the Cycle 11 refueling during the thermal shield repair outage in mid-1990, since RVLMS modifications will not be available by that time.
Cycle 11 refueling will then occur commencing in September 1991 instead, and the Cycle 12 refueling will occur commencing in late 1993.
With the proposed revision of License Condition 3.N, the Cycle 11 refueling will occur in mid-1990 and the Cycle 12 refueling will occur commencing in September 1992.
Hence, approval of the proposed revision will result in about a 12-month delay in the implementation of RVLMS (i.e., from September 1991 to September 1992).
The benefit of combining the thermal shield repair outage and the Cycle 11 refueling in mid-1990 is the elimination of one extended outage in the 1990 -
1993 period. As discussed in the enclosure, Edison concludes that the 12-month delay does not involve a significant hazards consideration.
ccordingly, Edison requests NRC approval of the enclosed Amendment plication No. 174.
Edison will be pleased to respond to questions or comments concerning this request and to meet with the NRC staff to provide additional information, as required. As discussed in my letter of October 2, 1989, we are proceeding in accordance with the associated outage schedule.
Sincerely, Enclosure cc:
J. B. Martin, Regional Administrator, NRC Region V C. Caldwell, NRC Senior Resident Inspector, San Onofre J. H. Hickman, California Department of Health Services