ML13333A584
| ML13333A584 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/14/1987 |
| From: | Medford M SOUTHERN CALIFORNIA EDISON CO. |
| To: | Prendergast K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML13333A582 | List: |
| References | |
| NUDOCS 8711240017 | |
| Download: ML13333A584 (5) | |
Text
Southern California Edison Company P. 0. BOXBoo 11 1 C A
i:
01 2244 WALNUT GROVE AVENUE ROSEMEAD. CALIFORNIA 91770 M.O.MEDFORD TELEPHONE MANAGER OF NUCLEAR ENGINEERING (818) 302-1749 AND LICENSING October 14, 1987 U. S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596-5368 Attention: Mr. K. Prendergast
Subject:
Docket Nos. 50-206, 50-361 and 50-362 San Onofre Nuclear Generating Station Units 1, 2 and 3 Emergency Plan The purpose of this letter is to provide formal responses to questions received during your phone call of July 30, 1987 with Mr. Phil Dooley regarding the SONGS Emergency Plan, Revision 2 dated May 15, 1987. Each of the sixteen (16) questions and/or items of concern, coupled with SCE's response is provided in the enclosure to this letter.
If you have any questions or would like additional information, please contact me.
Very truly yours, Enclosure cc:
J. B. Martin, Regional Administrator, NRC Region V F. R. Huey, NRC Senior NRC Resident Inspector, San Onofre Units 1, 2 and 8711240017 e71016 PDR ADOCK 05000206 F
PIDR
QUESTIONS AND RESPONSES The following NRC questions and/or concerns and SCE's responses directly regard Revision 2 of the SONGS Emergency Plan dated May 15, 1987.
- 1. NRC QUESTION/CONCERN:
- p. 4-2, last sentence:
Reword to state that notification of NRC will be made immediately after notification of state and local agencies.
SCE RESPONSE:
This change will be incorporated into the next Emergency Plan revision.
- 2. NRC QUESTION/CONCERN:
- p. 4-3:
Need an Emergency Action Level for unplanned loss of RHR/SDC for <10 minutes.
SCE RESPONSE:
This EAL will be incorporated into the next revision of the classification EPIP (SO1(23)-VIII-1), the Emergency Plan, and the Manual of Emergency Events.
- 3. NRC QUESTION/CONCERN:
- p. 4-3:
What is basis for # 9?
SCE RESPONSE:
Item No. 9 complies with item No. 7 of the Example Initiating Conditions for Notification of Unusual Events in NUREG-0654 and uses the Technical Specifications as a bases.
- 4. NRC QUESTION/CONCERN:
- p. 4-4, #10:
Other utilities classify this as an Alert.
SCE RESPONSE:
NUREG-0654 (page 1-5, # 9) classifies this as an Unusual Event.
- 5. NRC QUESTION/CONCERN:
- p. 4-3, # 6:
Include examples of these safety limits.
SCE RESPONSE:
These are included in EPIPs and will not be duplicated in the Emergency Plan.
- 6. NRC QUESTION/CONCERN:
- p. 4-3, 4-4:
Loss of SPDS or meteorological instrumentation is an Unusual Event in NUREG-0654, but not in the SONGS Emergency Plan.
SCE RESPONSE:
This is covered by item # 19 on page 4-4 of the SONGS Emergency Plan.
-2
- 7. NRC QUESTION/CONCERN:
- p. 5-8, para. 5.2.3:
"The Station Emergency Director will report to the TSC normally within I hour..." NUREG-0696 requires that the TSC be activated within 30 minutes.
SCE RESPONSE:
In accordance with the EPIP's, SCE is committed to actuate the TSC within one hour. SCE considers NUREG-0696 to be a guidance document. This position is consistent with our initial licensing position for San Onofre Units 2 and 3. SCE does not plan to revise this commitment and changes to the Emergency Plan are not necessary.
- 8. NRC QUESTION/CONCERN:
- p. 6-5, para. 6.1.3, 2, first sentence: Reword this so that it does not imply that the ESO is initially activated at a Site Area Emergency rather than an Alert.
SCE RESPONSE:
This wording is meant to imply that an event could initiate from the Site Area Emergency level.
Section 6.1.2 of the Emergency Plan describes activation of the ESO at the Alert level.
- 9.
NRC QUESTION/CONCERN:
- p. 7-2, # 4: Why was "125 VDC" removed from the description of the Control Room Emergency Lighting System?
SCE RESPONSE:
"125 VDC" will be re-incorporated into the next Emergency Plan revision.
- 10.
NRC QUESTION/CONCERN:
- p. 7-27, Table 7-3: What is the basis for removing the reference to the ERMS monitors in the E Plan?
SCE RESPONSE:
The ERMS monitors are no longer in service at SONGS.
-3
- 11.
NRC QUESTION/CONCERN:
- p. 8-3, first sentence: Do surveillances suffice in lieu of drills for Health Physics and Radiation Monitoring?
SCE RESPONSE:
As stated in Revision 2 to the Emergency Plan dated May 15, 1987, surveillances as described below suffice for drills in the areas of Health Physics and Radiation Monitoring.
SCE documented by internal correspondence in February 1986 the Emergency Plan drill requirements. These requirements included radiological monitoring and Health Physics drills; the Health Physics drills include semi-annual response to abnormal radiation levels and annual post-accident sampling and analysis. This SCE documentation established that these drill requirements were satisfied by performance of periodic surveillance procedures.
NUREG-0654 states in part that a drill is a supervised instruction period aimed at testing, developing and maintaining skills in a particular operation and that drills are to be evaluated. Radiological monitoring involving collection and analysis of radiological sample media (e.g.,
water and air) is conducted routinely at San Onofre. In addition, measurement and analysis of elevated airborne samples, liquid samples and direct radiation readings are routinely conducted. The practice of these activities is assured by completion of routine survey, environmental sample collection and effluent sampling and analysis surveillance procedures. Finally, routine use of post-accident sampling procedures and equipment is assured by completion of post-accident sampling system routine surveillance procedures.
The normal conduct of surveillances and routine practices satisfies the identified drill requirements because they are governed by quality affecting programs and supported by INPO accredited training programs.
Quality affecting programs are verified to be effective and to include corrective actions to identified deficiencies. INPO accredited training programs are verified to be effective, delivered by qualified instructors and include corrective actions to program deficiencies. Completion of surveillances and routine practices ensures timely testing, development and maintenance of these emergency response skill areas.
S(-4
- 12.
NRC QUESTION/CONCERN:
The Emergency Plan only discusses Protective Action Recommendations (PARs) based on radiological conditions (dose projections) and should include some discussion of PARs based on plant conditions (e.g.,
impending loss of containment, etc.)
SCE RESPONSE:
PARs based on plant conditions are included in EPIPs.
- 13.
NRC QUESTION/CONCERN:
- p. 4-7, 4-8: The Emergency Plan does not have an EAL at the Site Area Emergency classification for a Steam Generator Tube Rupture (SGTR) with a Loss of Offsite Power as discussed in NUREG-0654.
SCE RESPONSE:
At SONGS, a SGTR is classified as a Site Area Emergency on the basis of RCS leakage alone, regardless of the status of offsite power; this is considered to be conservative.
- 14. NRC QUESTION/CONCERN:
- p. 5-7, item e: Change to "Analyze interpreted plant and radiological data...
SCE RESPONSE:
This change will be incorporated into the next Emergency Plan revision.
- 15.
NRC QUESTION/CONCERN:
- p. 5-11, para. 5.2.9: Add to the list of responsibilities for the Chemistry Coordinator --
"advise the EC on effects from toxic chemicals."
SCE RESPONSE:
This addition will be incorporated into the next Emergency Plan revision.
- 16.
NRC QUESTION/CONCERN:
- p. 4-6 # 12: change to "Most all Control Room annunciators are lost."
SCE RESPONSE:
Addition of the word "most" in this case would confuse rather than clarify and the change, therefore, will not be made.