ML13333A304

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Ack Receipt of 780817 NRC Ltr Requesting Comments on Staff Evaluation of Systematic Evaluation Program for Subj Facil. Comments Incl
ML13333A304
Person / Time
Site: San Onofre 
Issue date: 10/03/1978
From: Haynes J
Southern California Edison Co
To: Ziemann D
Office of Nuclear Reactor Regulation
References
TASK-03-10.C, TASK-04-01.A, TASK-04-03, TASK-05-09, TASK-06-07.A2, TASK-06-07.D, TASK-07-01.B, TASK-17, TASK-3-10.C, TASK-4-1.A, TASK-4-3, TASK-5-9, TASK-6-7.A2, TASK-6-7.D, TASK-7-1.B, TASK-RR NUDOCS 7810110096
Download: ML13333A304 (4)


Text

Southern California Edison Company P.O. BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 October.3, 1978 Director of Nuclear Reactor Regulation Attention:

Mr. D. L. Ziemann, Chief Operating Reactors Branch #2 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Gentlemen:

Subject:

Docket No. 50-206 Systematic Evaluation Program San Onofre Nuclear Generating Station Unit 1 Mr. D. G. Eisenhut's letter of August 17, 1978 forwarded completed topic assessments for eight SEP topics. That letter requested that we examine the facts upon which the staff based its evaluation and respond either by confirming that the facts defining San Onofre Unit 1 are correct or by identifying any errors.

The results of our examination of the facts defining San Onofre Unit 1 in each topic assessment are provided as an enclosure to this letter.

Mr. Eisenhut's letter also forwarded a document out lining the NRC's intended documentation procedures for SEP. We have reviewed this document and have the following comments:

1. The first page of the document notes that SEP is unlike normal staff safety assessments in that the staff will be initiating unilateral reviews.

It is our understanding of SEP that the staff will not only be initiating but will also be unilaterally pursuing to completion the reviews of most of the SEP topics.

It is our hope that the statement set out at the first page of the document is not intended to deviate from that philosophy.

2. On page 4 of the document it is stated that information obtained informally from the licensee must at some later date be placed on the official docket or formally supplied to the NRC "in accordance with standard practice."

It is our understanding that an acceptable method of docu menting information will be for the NRC to include such

-2 information in meeting minutes. The statement on page 4 implies that a formal submittal will always be required.

The method of including information in meeting minutes should also be utilized.

If you have any questions on this matter, please contact me.

Very truly yours, J. G. Haynes Chief of Nuclear Engineering Enclosure

Enclosure Results of SCE Examination of Facts Defining San Onofre Unit 1 in NRC Topic Assessments III-10.C Surveillance Requirements on BWR Recirculation Pumps and Discharge Valves This topic assessment does not include information pertaining to San Onofre Unit 1.

IV-1.A Operation With Less Than All Loops in Service The NRC assessment of this topic includes the following statement with respect to San Onofre Unit 1:

"Five facilities (Yankee Rowe, Millstone 1, Ginna, Palisades, and San Onofre) are not authorized to operate with less than all loops in service, Technical Specifications restrict this mode to a period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at which time the facility must have the idle loop restored to service or shutdown."

The above statement is not correct for San Onofre Unit 1.

Technical Specification 3.1.2.D permits operation, albeit at reduced power, with 1, 2 or 3 reactor coolant pumps operating.

That specification reads as follows:

"D. Reactor power shall be limited in accordance with the number of coolant pumps operating as follows:

Minimum Number of Pumps Power (Nominal) 1 1% < P < 10%

2 10% < P < 60%

3 60% <

P <100%

The basis for permitting operation in the above modes is provided in Section 10.2 of the Final Engineering Report and Safety Analysis.

IV-3 BWR Jet Pump Operating Indications This topic assessment does not include information pertaining to San Onofre Unit 1.

-2 V-9 Reactor Core Isolation Cooling System This topic assessment does not include information pertaining to San Onofre Unit 1.

VI-7.A.2 Upper Plenum Injection This topic assessment does not include information pertaining to San Onofre Unit 1.

VI-7.D Long Term Cooling Passive Failures There are no facts defining San Onofre Unit 1 utilized by the NRC in their evaluation of this topic.

VII-l.B Trip Uncertainty and Setpoint Analysis Review of Operating Data Base There are no facts defining San Onofre Unit 1 utilized by the NRC in their evaluation of this topic.

XVII Operational QA Program The NRC assessment of this topic references the following document as the basis for acceptance:

"Safety Evaluation Report, 4/8/75."

This reference is incorrect. The correct date of the Safety Evaluation Report is 4/15/75.