ML20206M068
| ML20206M068 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/10/1999 |
| From: | Scherer A SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9905140186 | |
| Download: ML20206M068 (3) | |
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'May,10 -1999-U; S. Nuclear Reg'ulatory Commission Documeat Control Desk Washington, D. C. 20555 -
Subject:
Docket Nos. 50-361 and 50-362 incorrect information in Amendment Request Submittal San Onofre Nuclear Generating Station, Units 2 and 3
Reference:
1.
Letter, Dwight E. Nunn (SCE) to Document Control Desk (NRC), Subject, " Proposed Technical Specification Change Number NPF-10/15-475, San Onofre Nuclear Generating Station Units 2 and 3," dated June 30,1997 2.
Letter, James W. Clifford (NRC).to Harold B. Ray (SCE), Subject, " Issuance Of Amendment For San Onofre Nuclear Generating Station, Unit No. 2 (TAC No.
MA0236) and Unit No. 3 (TAC No. MA0237)," dated December 22,1998 The purpose of this letter is to correct information contained in our Reference 1 submittal.
This information was previously discussed with our NRC Project Manager.
By Reference 1, Southem Califomia Edison (SCE) requested amendments to the Facility Operating Licenses for San Onofre Nuclear Generating Station Units 2 and 3 (SONGS 2
& 3). One of the changes requested was the deletion of License Condition 2.C.(19)b,
" Shift Manning," from SONGS Unit 2 license NPF-10. The Enclosure to Reference 1 stated:
"The proposed change would delete SONGS Unit 2 License Condition 2.C.(19)b,
' Shift Manning.' Since implementation of NRC Amendment Numbers 127 and 116, overtime restrictions identified in License Condition 2.C.(19)b, conflict with the overtime provisions currently specified in the SONGS Units 2 and 3 Topical Report.
This conflict is only applicable to SONGS Unit 2 because the license condition is -
specific to SONGS Unit 2 only. For SONGS Unit 3, the shift manning requirements are specified in the Topical report. [ Technical Specification) Section 5.2.2.e, contains requirements for administrative controls, the details are now contained in
.the Topical Report."
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. P. O. Box ' 28 (
1 LSan Clemente, CA 92674 0128 949 368-7501-
/ Fax 949 368 7575 I
1, i
Document Control Desk May 10, 1999 The stated inforrr,ation in Reference 1 was incorrect in that overtime provisions were not contained in the Topical Report at the time Reference 1 was submitted. Instead, the detailed overtime provisions were contained in a controlled site procedure.
By Reference 2, the NRC issued an amendment to the SONGS Unit 2 Facility Operating License authorizing deletion of License Condition 2.C.(19)b as requested. The Safety Evaluation enclosed with Reference 2 stated in part:
"The licensee in its submittal stated that the information included in this license condition conflicts with that which is included in the SONGS Topical Report that has been implemented as part of the !!consee's adoption of the improved Technical Specifications (ITS). Further, the staff in its safety evaluation approving the ITS for SONGS noted that specific overtime limits need not be included in the T[echnical] -
S[pecifications] but may be controlled by administrative procedures. This change does not affect the current staffing policies, commitments, or implementation at the site. Since this license condition serves no purpose and the staffing requirements and guidelines are included in the SONGS Topical Report which provided the appropriate level of administrative control for the issue of staff manning, the staff
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hereby approves deletion of SONGS Units 2 License Condition 2.C.(19)b."
Again, the statement that specific overtime limits were included in the SONGS Topical l
Report was incorrect. Instead, overtime provisions were contained in a controlled site procedure.
Upon identification of this discrepancy, SCE advised the NRC Project Manager and Resident inspector and conducted an investigation to determine the cause. This invastigation concluded that human performance errors occurred in the preparation of Reference 1: specifically, (a) the individual preparing Reference 1 did not exercise sufficient attention to detail by assuming without verification that the specific overtime limits had been transferred to the Topical Report, (b) the supervisor of the individual failed to provide adequate oversight, and (c) there was an incomplete internal review of Reference
- 1. Corrective action has been taken by the Manager, Plant Licensing, to review this event with licensing engineers and supervisors who make submittals to the NRC, emphasizing the lessons learned.
in addition, SCE will revise the Topical Report by June 1,1999 to include the specific overtime limits which were contained in the controlled site procedure. In the future, however, SCE may relocate the overtime limits to another controlled document deemed more suitable, such as the Updated Final Safety Analysis Report.
3 o.
1 Document Control Desk May 10, 1999 SCE continually strives to provide complete and accurate information to the NRC. We consider this event a serious lapse on our part, and sincerely regret the error, if you have any questions regarding this event, please do not hesitate to contact me or Mr. Jack Rainsberry at (949) 368-7420.
Sincerely, cc:
E. W. Merschoff, Regional Administrator, NRC P agion IV J. A. Sloan, NRC Senior Resident Inspector, San Onofre Units 2 & 3 L. Raghavan NRC Project Manager, San Onofre Units 2 and 3 1