ML20086Q752
| ML20086Q752 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/29/1984 |
| From: | Stoffel J EG&G, INC. |
| To: | NRC |
| Shared Package | |
| ML13309B417 | List: |
| References | |
| CON-FIN-A-6483, RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, NUDOCS 8402280122 | |
| Download: ML20086Q752 (16) | |
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ENCLOSURE
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l CONFORMANCE TO REGULATORY GUIDE 1.97 SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3 J. W. Stoffel Published February 1984 EG&G Idaho, Inc.
.i Prepared for the U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Under 00E Contract No. DE-AC07-76ID01570 FIN No. A6483 b
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3 CONFORMANCE TO REGULATORY GUIDE 1.97
-SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3 1.
INTRODUCTION On December 17, 1982, Generic Letter No. 82-33 (Reference' 1) was issued by D. G. Eisenhut, Director of the Division of Licensing, Nuclear Reactor Regulation, to all licensees of operating reactors, applicants for operating licenses and holders of construction permits. This letter included additional clarification regarding Regulatory Guide 1.97, Revision 2 (Reference 2), relating to the requirements for emergency
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respon'se capability. These requirements have been published as Supplement 1 to NV. REG-0737, "TMI Action Plan Requirements" (Reference 3).
Southern California Edison Company, the licensee for San Onofre Nuclear. Generating Station Units 2 and 3, provided a response:to the Regulatory Guide 1.97, Revision 2, on May 13, 1982 (Reference 4).
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This interim report providesLan evaluation of this submittal.
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REVIEW REQUIREMENTS Section 6.2 of NUREG-0737, Supplement 1, sets forth the documentation to be submitted in a report to NRC describing how the applicant meets the guidance of Regulatory Guide 1.97 as applied to emergency response facilities. The submittal should include documentation that provides the following information for each variable shown in the applicabla table of Regulatory Guide 1.97.
1.
Instrument range 2.
Environmental qualification y
3.
Seismic qualification I
4 4.
Quality assurance 5.
Redundance and sensor location 6.
Power supply 7.
Location of display 8.
Schedule of installation.or upgrade.
Further, the subm'ittal should identify deviations from the guidance in the Regulatory Guide and provide supporting justification or alternatives.
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i Subsequent to the issuance of the generic letter, the NRC held regional meetings in February and March 1983 to answer licensee and
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applicant questions and concerns regarding the NRC policy on this matter.
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At these meetings, it was noted that the NRC review would only address
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exceptions taken to the guidance of Regulatory Guide 1.97.
Further, where
~ 1icensees or applicants explicitly state that instrument systems conform to the' provisions of the guide it was noted that no further staff review would be necessary. Therefore, this report only evaluates the exceptions to-the guidance of Regulatory Guide 1.97.
The'following evaluation is an audit of the licensee's submittal based on the review policy described in the NRC regional meetings.
3.
EVALUATION 4
The licensee provided a response to the NRC generic letter 82-33 on.
May 13,1982 (Reference 4).
This evaluation is based on that submittal.
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3.1 Adherence to Reculatory Guide 1.97 The licensee stated that the existing and planned plant instrumentation is consistent with Regulatory Guide 1.97, Revision 2, except for the deviations identified in Section III of Reference 4.
Therefore, it is concluded that the licensee h'as provided an explicit commitment on conformance to the guidance of the Regulatory Guide, except 2
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T for those exceptions that were justified as noted in Subsection 3.3.
The information provided by the licensee (Reference 4) predated Generic Letter No. 82-33 and did not include the information identified as Items 1 through 8 (e.g., instrument range, etc.) in Section 2 of this report. This information should be provided to document the licensee's commitment on conformance to Generic Letter No. 82-33.
3.2 Tyoe A Variables Regulatory Guide 1.97 does not specifically identify Type A variables that provide,information required for opera' tor controlled safety actions.
The licensee classified the following instrumentation chaanels as Type A variables.
1.
Neutron flux 2.
Reactor Coolant System (RCS) hot leg temperature 3.
RCS cold leg temperature 4.
RCS pressure-5.
Refueling water storage tank level 6.
Containment pressure 7.
Containment sump water level 8.
Containment hydrogen concentration 9.
Coolant icvel in reactor (reactor vessel level monitoring system) s 10.
High pressure safety injection flow 11.
Core exit temperature (thermocouples) 3 i
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12.
Steam generator level 13.
Steam generator pressure.
All the above variables are also included as type B, C or D variables, and meet Category 1 requirements consistent with the requirements for Type A variables except for 1, above (neutron flux). The licensee has committed to replace the neutron flux instruments with qualified instruments in accordance with 10 CFR 50.49.
' '3.3 Exceotions to Regulatory Guide 1.97 The licensee identified the following exceptions to the requirements of Regulatory Guide 1.97.
3.3.1 Reactor Coolant System Pressure This instrument complies with the Category I requirements.
The range of the instrument is not as recommended by Regulatory Guide 1.97 (0 to 4000 psig).
The instrumentation provided covers a range of 0 to 3000 psig.
The licensee's justification for this deviation is that this' range is adequate pending resolution of the anticipated transient without scram (ATWS) issue.
The existing range of 0-3000 psig is adequate to monitor all expected pressures based on the accident analyses presented in Chapter 15 of the plant FSAR.
Therefore, we find this deviation acceptable, but require a commitment from the licensee to install Category 1 instrumentation with a range in accordance with the resolution of the ATWS issue if pressures are found to exceed those currently presented in the FSAR.
3.3.2 Meactor Coolant System Hot and Cold Log Water Temoerature The instrumentation provided for this variable has a range of 50*F to 710*F rather than 50*F to 750*F as recommended by Regulatory Guide 1.97, Revision 2.
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Regulatory Guide 1.97, Revision 3, May 1983, recommends a range of 50*F to 700*F for these variables. The instrumentation supplied by the licensee exceeds this recommended range and therefore is acceptable.
3.3.3 Accumulator Tank Level and Pressure Level The licensee takes exception to the level range recommended by Regulatory Guide 1.9,7, Revision 2 (10% to 90% volume). The licensee states that the existing range of 0 to 378 inches " meets the' intent."
The instrumentation for' this variable reads 0 to 100% (FSAR Vol.15, Table 7.5-1).
Since the range of the instrument was not related to the percent of volume in the accumulator, a judgement can not be made that the
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range provided is adequate to monitor the operation of the accumulator under post-accident conditions.
The licensee should provide justification that the range is adequate to monitor the operation' of the accumulators or that such information can be determined based on some other parameter.
Pressure The licensee takes exception to the pressure range recommended by Regulatory Guide 1.97, Revision 2 (0 to 750 psig).
The provided instrumentation has a range of 0 to 700 psig. The licensee' states that this meets the intent.
The licensee's' technical specification (Section.16.3.5.1.1), requires a nitrogen cover pressure of between 600 and 610 psig.
This pressure is manually controlled. The existing range of 0-700 psig is an acceptable deviation for these units because it adequately covers the expected range of accumulator pressure.
The licensee states that environmental qualification upgrade is not y
warranted for the level and pressure instrumentation because there are diverse ways to obtain core cooling information following a LOCA.
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s Environmental qualification has been subsequently clarified by the environmental qualification rule, 10 CFR 50.49.
It is concluded that the guidance of Regulatory Guide 1.97 has been superseded' by a regulatory requirement. Any exception to this rule is beyond the scope of this review and should be addressed in accordance with 10 CFR 50.49.
3.3.4 Steam Generator pressure The licensee has provided instrumentation for this variable with a range of 0 to 1200 psig.
The recommended range is from atmospheric pressure to 20% ibove the lowest safety valve setting.
The lowest safety valve setting is 1100 psig (Technical Specification Table 16.4-15).
This requires a range of 1320 psig to meet the Regulatory Guide 1.97 recommendation.
The licensee's justification for this deviation is that the basis for 20% above the lowest safety valve setting is arbitrary.
Existing instrumentation provides a range to 9.1% above the icwest safety valve setting, and extension of the range would disrupt calibration of
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safety. equipment.
The San Onofre Units 2 and 3 Final Safety Analysis Report (Reference 5) shows a maximum anticipated steam generator pressure of 1155 psig.
This analysis assumes a complete loss of turbine generator load, a reactor trip on high pressurizer pressure, anc operation of the safety valves within their specifications.
Relief valve setpoints, while typically specified as 1% of nominal, routinely exhibit a repe'atability scatter on the order of 3%.
Such a variation in relief valve setpoint in combination with reasonable instrumentation chain sensor-to readout inaccuracy and drift (25%) could eliminate any instrumentation margin.
,Given that the existing instrumentation margin may be non-existent, and that the instrumentation cou'ld be recalibrated, we do not consider the licen'spe's justification for this deviation to be adequate.
v 3.3.5 Auxiliary Feed Water Flow The licensee states that the current instrument does not meet the range requirement of Regulatory Guide 1.97 (to 110% of normal design flow).
The installed instrumentation range is 0-800 gpm and the pump 6
3 normal design flow is 860 gpm. The current range is 937. of normal design flow. The licensee further states that a new instrument, or justification for the existing one, will be incorporated with the auxiliary feed water system redesign planned for first refueling.
The licensee needs to provide a commitment to install instrumentation that meets Regulatory Guide 1.97 recommendations, or justification for the existing range.
3.3.6 Containment Sumo Water Temoerature Regulato'ry Guide l'.97 recommends that the conta'inment sump water temperature be measured for a range of 50 to 250*F.
The licensee does not believe that it is necessary to install an instrument to read this variable. The licensee states that there is no defined need for this information and there are alternatives available to obtain this information should it be needed.
We find the licensee's justification for this deviation unacceptable.
In order to monitor operations of the containment cooling systems, the licensee shoul'd provide the sump temperature instrumentation in accordance with Regulatory Guide 1.97 or identify the alternate source (s) of instrumentation that provides the same information and satisfies the regulatory guide recommendations.
3.3.7 Component Cooling Water Temoerature to ESF System The licensee takes exception to the range recommended by Regulatory Guide 1.97 (32*F to 200*F).
He states that the existing instrumentation with the high range to 150*F meets the intent of Regulatory Guide 1.97. We find the licensee's justification for this deviation unacceptable, s
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The licensee should provide basis that shows the range (150*F) exceeds any expected component cooling water temperature with adequate instrumentation margin, or provide the high range of 200 F as recommen'ded by the Regulatory Guide.
3.3.8 Reactor Coolant System Soluble Baron Concentration The licensee,does not propose to change the existing boron concentration range (10.to 5000 ppm) to the recommended range (0 to 6000 ppm).
The licensee states that the existing instrumentation meets the intent of Regul'atory Guide 1.97.
He further mentions that boron,
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measurement can be obtained grab samples.
We find the licensee's justification for this deviation unacceptable.
The licensee should provide analysis that shows his existing monitoring instrumentation will adequately cover the maximum expected boron concentrations, or provide instrumentation with the recommended range
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identified in Regulatory Guide 1.97.
3.3.9 Ouench Tank Temperature The licensee takes exception to the temperature range recommended by the Regulatory Guide (50*F to 750'F). The justification presented by the
' licensee is that the present 300'F upper range is unlikely to be exceeded because the rupture disc will blow'.
We concur that the existing ipstrumentation may be adequate during most normal operating conditions, but since Regulatory Guide 1.97
. recommendations are to assess plant conditions during and following an accident, this deviation is not acceptable. The licensee should show that the t'emperature will remain within the 300*F range for all postulated accidekt conditions or provide the recommended range identified in Regulatory Guide 1.97.
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I 3.3.10 Main Feedwater Flow The licensee's existing instrumentation covers a range up to 6
8.0 x 10 lb/hr, which is 105% of design flow.
Regulatory Guide 1.97 recommends a range of 110% of design flow, which would require up to 6
8.3 x 10 lb/hr.
The only justification for this deviation given by the licensee is that the existing instrumentation meets the intent. We find the licensee's justification for this deviation accentable.
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3.3.11 Radioactive Gas Holduo Tank pressure Regulatory Guide 1.97 recommends a range of 0 to 150% of design pressure for this instrumentation. The licensee has supplied
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instrumentation for this variable with a ra'nge of 0 to 400 psig, which is 114% of the design pressure of the vessel.
The licensee's justification for this deviation is that a safety valve on the tank lifts at 350 psig, preventing the design pressure of 350 psig from being. exceeded.
Per Regulatory Guide 1.97,' the purpose of this instrumentation is to indicate storage capacity.
The operating range of the instrumentation covers not only this operating range but also the safety valve lift pressure.
Therefore, we find the deviation acceptable.
3.3.12 Quench Tank Level The licensee takes exception to the top to bottem range recommended by Regulatory Guide 1.97.
The supplied instrumentation covers a range of 0 to 48 inches (0 to 66%).
The licensee's justification for this deviation is tSgt any large release from the pressurizer safety valves would blow the rupture disc, and that the present range meets the intent.
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t, Since the provided instrumentation only covers 2/3 of the tank volume and the purpose of the recommended range is to assess plant conditions during and following an accident, we find this deviation unacceptable.
The licensee should provide an analysis that shows the instrumentation is sufficient to monitor the expected range of operation.
3.3.13 Ouench Tank pressure The licensee takes exception to the range (0 to design pressure)
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recommended by Regulatory Guide 1.97.
The supplied instrumentation provides a range of 0 to 25 psig on a tank with 130 psig design' pressure.
The justifications provided by the licensee are:.(a) any large' relief would blow the rupture disc, (b) any pressurizer safety valve leakage above design normal of 3 psig will be detected, (c) tank safety valve is set at 130 psig, and (d) present range of 25 psig meets intent.
' We concur that'the existing instrumentation is adequate during most normal operating conditions; however, Regulatory Guide 1.97 recommendations
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are to assess plant conditions during and following an accident. We therefore find these justifications inadequate and the deviation
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unacceptable. The licensee should provide sufficient instrument range to cover the anticipated pressures that would blow the rupture disc during and following an accident.
3.3.14 Radiation Exposure Rate The licensee takes exception to the instrument range recommended by
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Regulatory Guide 1.97 (10 R/hr t'o 10 R/hr).
Currently installed
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area radiation monitors cover the range of 10 to 10 mrem /hr.
The licensee's justification for this ' deviation is that this range is adequate to det. ermine if a specific area is accessible, based on th'e analysis done for TML NUREG 0737 Item II.B.2., and that area monitors can be augmented by local portable monitors.
From a radiological standpoint, if the radiation levels reach or excecd the upper limit of the range (10 R/hr), personnel would not be 10
3 permitted access to the areas except for life saving. We therefore find
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the proposed range (10 to 10 mrem /hr) for the radiation exposure rate monitors acceptable.
3.3.15 Radioactivity Concentration or Radiation Level in Circulating Primary Ccolant 4
1 The licensee does not consider this continuous measurement to be necessary. The justification given by the licensee is that no qualified instrumentation for this variable is available, and this measurement can be obtained us,in,g the post-accident sampling system.
Instrumentation that is suitable for this variable has been under research and development. We concur that the instrumentation presently provided for this variable is acceptable on an interim basis on the I
condition that the licensee (a) commit to evaluate systems fo.r this J
variable as they become available and (b) commit to installation of a satisfactory system within a reasonable time frame after availability.
1 Chemical and Volu' e Control System letdown Flow-Out 3.3.16 m
The licensee states that environmental qualification of this i
instrumentation is not required because letdown flow is isolated and will not be used post-LOCA.
Environmental qualification has been subsequently clarified by the 7
environmental qualification rule,10 CFR 50.49.
It is concluded that the guidance of Regulatory Guide 1.97 has been superseded by a regulatory t
l requirement. Any exception to this rule is beyond the scope of this review and should be addressed in accordance with 10 CFR 50.49.
3.3.17 Accident Samoling Caoability (Analysis Capability on Site) v The licensee takes exception to providing on-site analysis capability for chloride.
The licensee's justification is that offsite analysis capability exists using post-accident sampling system grab samples.
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Regulatory Guide 1.97 recommended time for taking and analyzing chloride samples is within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Since the licensee does not indicate where these offsite samples must be sent or the time frame involved to get the results, this deviation is not adequately justified.
4.
CONCLUSIONS Based on our review we find that the licensee conforms to, or is
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justified in deviating from the guidance of Regulatory Guide 1.97, with the following exceptions:
1.
Provide the information identified in Section 2, to document the licensee's commitment on conformance to Generic Letter No. 82-33 (see Section 3.1).
l 2.
Reactor Coolant System Pressure--This instrument covers a range of 0 to 3000 psig.
Regulatory Guide 1.97 recommends 0 to 4000 psig for the San Onofre Units 2 and 3 design.
A commitment to install instrumentation with a range in accordance with the ATWS resolution is needed from the licensee (see Subsection 3.3.1).
3.
Accumulator Tank Level and Pressure--The level instrument covers a range of 0 to 378 inches.
Regulatory Guide 1.97 recommends a range of 10 to 90% volume. Based on the licensee's submittal we cannot determine that 0 to 378 inches meets the regulatory guide recommendations.
Environmental qualification needs to be addressed in accordance with 10 CFR 50.49 (see Subsection 3.3.3).
4.
Steam Generator Pressure--The supplied instrumentation covers a range of 0 to 1200 psig.
The recommended range is 20% above the
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lowest safety valve setting of 1100 psig.
The licensee should provide sufficient justification for this deviation (see Subsection 3.3.4).
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Auxiliary Feedwater Flow--The licensee states they intend to change, or justify not changing, the existing instrumentation for this variable. Without knowing what new instrumentation is proposed, or what justification might be intended, we cannot determine whether the recommendations of Regulatory Guide 1.97 will be met (see subsection 3.3.5).
6.
Containment Sump Water Temperature--The licensee proposes not to implement the installation of this instrumentation.
The justification provided by the licensee is unacceptable. The licensee should provide the sump temperature instrumentation in accordance with Regulatory Guide 1.97, or provide justification that an alternate source can satisfy the requirements of the regulatory guide (see Subsection 3.3.6).
7.
Component Cooling Water Temperature to ESF System--The licensee
. proposes. to continue operating with an instrument that has a upper range limit of 150*F instead of 200*F as recommended by Regulatory Guide 1.97.
The justification present'ed by the licensee is unacceptable. The licensee should provide an analysis that shows that 150*F exceeds any expected component cooling water temperature (see Subsection 3.3.7).
8.
Reactor Coolant System Soluble Baron Concentration--The licensee states that the existing instrument range for boron concentration (10-5000 ppm) meets the intent of the O to 6000 ppm range the Regulatory Guide recommends. The licensee should provide justification for thi.s deviation in the form of analysis that shows their existing monitoring instrumentation will adequately cover the maximum expected baron concentration, or provide the recommended range identified in the regulatory guide (see Subsection 3.3.8).
s 9.
Quench' Tank Temperature--The licensee states that the installed instrument with a range of 0 to 300*F is adequate.
Regulatory i
Guide 1.97 recommends 50*F to 750*F.
The licensee is relying on 13
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6 the rupture disc to prevent temperatures in excess of 300'F.
The licensee should provide analysis that shows that the temperature will remain within the 300*F range for all postulated accident conditions, or provide the recommended range identified in the regulatory guide (see Subsection 3.3.9).
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- Quench Tank Level--The licensee states that the provided level instrumentation that covers a range of 2/3 the tank volume is adequate.
Regulatory Guide 1.97 recommends reading from top to bottom of the tank with this instrumentation. The licensee is relying on the blowing of the rupture disc to keep the level i
within the existing range of this instrument. The justification presented by the' licensee is unacceptable.
The licensee should provide analysis that shows the existing instrumentation is sufficient to monitor the expected range of operation, or provide the recommended range identified in the regulatory guide (see Subsection 3.3.12).
11.
Quench Tank Pressure--The licensee states that the installed instr.umentation with a range of 0 to 25 psig meets the intent of Regulatory Guide 1.97.
The recommended range is to design pressure (130 psig).
The justification provided by the licensee is unacceptable.
The Itcensee should provide the recommended range of 130 psig so that the operators can assess the pressure in the quench tank during' and foll' Ying an accident (see o
Subsection 3.3.13).
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12.
Radioactivity Concentration or Radiation Level in Circulating Primary Coolant--The licensee proposes to meet this recommendation by grab sample analysis instead of a continuous indicating instrument with a range 1/2 to 100 times the technical specification limit in R/hr.
The existing instrumentation is' acceptable on an interim basis. The licensee needs to commit to installing newly developed instrumentation for this variable (see Subsection.3.3.15).
13.
Chemical and Volume Control Letdown Flow-Out--Environmental quajification needs to be addressed in accordance with 10 CFR 50.49 (See Subsection 3.3.16).
14.
Accident Sampling Capability (Analysis Capability on Site)--The licensee intends to meet this recommendation for chloride by taking grab samples and sending them off site for a'nalysis.' The licensee should p'rovide sufficient justification with respect to the time frame for this deviation (see Subsection 3.3.17).I 5.
REFERENCES s
1.
NRC letter, D. G. Eisenhut to all licensees of operating reactors, applica6ts for operating licenses, and holders of construction
, permits, " Supplement No. I to NUREG-0737--Requirements for Emergency Response, Capability (Generic Le.tter No. 82-33)," December 17, 1982.,
2.
Instrumentation for Light-Water-Cooled Nuclear Power plants to Assess Plant and Environs Conditions Ouring and Following an Accident, Regulatory Guide 1.97, Revision 2, U.S. Nuclear Regulatory Commission (NRC),OfficeofStandards,Oevelopment, December 1980.
1 3.
Clarification of TMI Action Pian Recuirements, Reouirements for i
Emergency Resoonse Capability, NUREG-0737 Supplement No. 1, NRC, Office of Nuclear Reactor Regulation, January 1983.
4.
Southern California Edison Company (SCE) letter K. P. Baskin to s Director, Office of Nuclear Reactor Regulation, May 13, 1982.
5.
Final Safety Analysis Report, San Onofre Nuclear Generating Station, I
Units 2 and 3, revised through Amendment 12, dated October, 1978, j
Figure 5.2 A-1.
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