NUREG-0829, Summary of 890501 Meeting W/Util Re full-term OL Items, Thermal Shield & Items Requiring Resolution Before Startup. Attendance List,Nrc Agenda & Util Viewgraphs Encl

Summary of 890501 Meeting W/Util Re full-term OL Items, Thermal Shield & Items Requiring Resolution Before Startup. Attendance List,Nrc Agenda & Util Viewgraphs Encl

ML13336A199
Person / Time
Site:	San Onofre
Issue date:	05/16/1989
From:	Trammell C Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
REF-GTECI-A-47, REF-GTECI-SY, RTR-NUREG-0829, RTR-NUREG-829, RTR-REGGD-01.097, RTR-REGGD-1.097, TASK-A-47, TASK-OR NUDOCS 8905300251
Download: ML13336A199 (40)

Text

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 May 16, 1989 LICENSEE:

Southern California Edison Company FACILITY:

San Onofre Nuclear Generating Station, Unit No. 1

SUMMARY

OF MEETING HELD ON MAY 1, 1989 TO DISCUSS FULL-TERM OPERATING LICENSE ITEMS, THERMAL SHIELD, AND OTHER ITEMS REQUIRING RESOLUTION BEFORE UNIT STARTUP On May 1, 1989, the NRC staff met with representatives of Southern California Edison (SCE) to discuss the full-term operating license requirements and issues in need of resolution before plant startup, including the thermal shield amendment request. Persons attending the meeting are identified in Enclosure 1.

The meeting agenda as presented by the NRC staff is contained in Enclosure 2.

Viewgraphs shown by SCE are contained in Enclosure 3.

The purpose of the meeting was threefold:

1. to develop the schedule for all remaining issues needed for converting the provisional operating license to a full-term operating license (FTOL),

2. to determine additonal actions needed to resolve the thermal shield issue, and

3. to resolve all issues for plant startup as identified in the Region V Confirmatory Action Letter of January 31, 1989 (and supplemented February 8, 1989).

The FTOL items consist of Three Mile Island Action Plan items, Systematic Evaluation Program items (NUREG-0829), Generic Letters (multi-plant actions),

and Other, as identified on p. 2 of Enclosure 2. All of these items will be completed by the end of Cycle XI refueling except as follows:

TMI Items Control Room Habitability - Cycle XII DCRDR

- Cycle XII R.G. 1.97 and SPDS

- under evaluation.

Schedule to be set by integrated living schedule (ILS)

Generic Letter Items Degraded Grid relays

- Cycle XII TDI Crankshaft

- ILS D95'-__25"1 SVO5T6_

PDR ADOCK 50)002QA P Pj~f i

-2 SEP Items SMS Enhancements (injection only) - Cycle XII Failure Mode Analysis

- ILS SG Overfill

- to be resolved with resolution of USI A-47.

In the "Other" category, the charging pump motor would be rewound for a power rating of 1000 hp to support the SIS enhancements scheduled for Cycle XII. In response to this presentation, the NRC staff requested that SCE document these schedules and include SCE's rationale for the schedules. The matter will be reviewed further when the letter is received.

The second part of the meeting was devoted to the thermal shield amendment.

SCE proposes a mid-cycle outage for a visual inspection of the thermal shield combined with a steam generator tube inspection. In addition, SCE would improve the monitoring program based on NRC staff comments. Acceptance criteria for the inspection at mid-cycle would be developed with the NRC staff following return of the unit to operation.

The third part of the meeting was devoted to a discussion of the Confirmatory Action Letter and future operation in Cycle X.

The February 8, 1989 followup letter to the January 31, 1989 Confirmatory Action Letter requested that SCE reassess the readiness of Unit 1 to return to operation, considering several plant design deficiencies which have been recently identified. In particular, the NRC requested that SCE evaluate the adequacy of their actions to correct the underlying root causes of the various deficiencies.

SCE stated during the meeting that they had reevaluated their readiness for Unit 1 restart, as requested by the NRC's February 8 letter, and had concluded that the plant is safe to restart. SCE stated that the detailed results of their evaluation are documented in letters to the NRC dated March 17, 1989 and April 28, 1989.

SCE summarized the principal bases for their conclusion that Unit 1 is safe to restart, as follows:

1. The recently identified design deficiencies are relatively subtle and complex and were not self-revealing. Each of the deficiencies was identified by enhanced SCE engineering and test efforts that were specifically implemented to discover and correct these types of problems.

2. The root causes which have allowed these problems to occur are attributable to engineering.deficiencies that have been previously recognized and for which corrective actions have been initiated (principally in the areas of engineering reorganization, enhanced attention to technical detail, and improved design basis document preparation).

-3

3. Each of the identified design deficiencies has been determined to be of relatively low safety significance, whether considered individually or in combination. In this regard, SCE stated that it is reasonable to conclude that any remaining plant deficiencies (which are yet to be identified by longer range corrective actions) will involve similar limited safety significance.

The NRC representatives concurred with the licensee's characterization of the identified problems and recognized that programs have been established to identify other potential deficiencies. The NRC representatives also understood that other design deficiencies may well be identified by these ongoing programs (e.g., enhanced engineering/design activities, design basis upgrade program) and expressed their expectation they they will be assessed and handled consistent with established procedures and the requirements of the facility's license.

In response to questions raised by the NRC during the meeting, SCE committed to provide the following additional information to assist the NRC staff in completing its evaluation of the SCE restart proposal:

1. An assessment of what actions remain to finalize the root cause evaluation for any problems for which only preliminary evaluations have been completed.

2. An assessment of remaining actions to resolve concerns associated with (1) design temperature limitations on the RHR heat exchangers during load rejection events and (2) potential cavitation of CCW pumps following the loss of instrument air to RHR heat exchanger throttle valves.

The licensee subsequently resolved these issues to the staff's satisfaction by completing all root cause evaluations prior to startup, by completing initial calculations demonstrating that the RHR heat exchanger temperature limits are satisfactorily met during load rejection events, and by completing an evaluation which demonstrated the acceptability of CCW pump operation with loss of instrument air for 30 days.

Charle M.

Trammel, Senior Project Manager Project Directorate V Division of Reactors Projects III, IV, V and Special Projects Office of Nuclear Reactor Regulation

Enclosures:

1. Attendees

2. NRC Agenda

3. SCE Viewgraphs cc:

See next page

May 16, 1989 3

3. Each of the identified design deficiencies has been determined to be of relatively low safety significance, whether considered individually or in combination. In this regard, SCE stated that it is reasonable to conclude that any remaining plant deficiencies (which are yet to be identified by longer range corrective actions) will involve similar limited safety significance.

The NRC representatives concurred with the licensee's characterization of the identified problems and recognized that programs have been established to identify other potential deficiencies. The NRC representatives also understood that other design deficiencies may well be identified by these ongoing programs (e.g., enhanced engineering/design activities, design basis upgrade program) and expressed their expectation they they will be assessed and handled consistent with established procedures and the requirements of the facility's license.

In response to questions raised by the NRC during the meeting, SCE committed to provide the following additional information to assist the NRC staff in completing its evaluation of the SCE restart proposal:

1. An assessment of what actions remain to finalize the root cause evaluation for any problems for which only preliminary evaluations have been completed.

2. An assessment of remaining actions to resolve concerns associated with (1) design temperature limitations on the RHR heat exchangers during load rejection events and (2) potential cavitation of CCW pumps following the loss of instrument air to RHR heat exchanger throttle valves.

The licensee subsequently resolved these issues to the staff's satisfaction by completing all root cause evaluations prior to startup, by completing initial calculations demonstrating that the RHR heat exchanger temperature limits are satisfactorily met during load rejection events, and by completing an evaluation which demonstrated the acceptability of CCW pump operation with loss of instrument air for 30 days.

Original signed by G. Knighton for Charles MTrammell, Senior Project Manager Project Directorate V Division of Reactors Projects III, IV, V and Special Projects Office of Nuclear Reactor Regulation

Enclosures:

1. Attendees

2. NRC Agenda

3. SCE Viewgraphs cc: See next page DISTRIBUTION Docket File NRC & LPDRs JSniezek PD5 Reading GKnighton.CTrammel OGC EJordan BRimes AThadani JRichardson FHuey JPartlow FMiraglia TMurley ACRS (10)

MJohnson CGreen

• See previous concurrence DRSP/PD5*

DRSP/D:PD5*

GV O/

CTrammell GKnighton Martin 5115/89 5/15/89 5//4/Ftq

May 16, 1980

-3

3. Each of the identified design deficiencies has been determined to be of relatively low safety significance, whether considered individually or in combination. In this regard, SCE stated that it is reasonable to conclude that any remaining plant deficiencies (which are yet to be identifieo by longer range corrective actions) will involve similar limited safety significance.

The NRC representatives concurred with the licensee's characterization of the identified problems and recognized that programs have been established to identify other potential deficiencies. The NRC representatives also understooo that other design deficiencies may well be identified by these ongoing programs (e.g., enhanced engineering/design activities, design basis upgrade program) and expressed their expectation they they will be assessed and handled consistent with established procedures and the requirements of the facility's license.

In response to questions raised by the NRC during the meeting, SCE committed to provide the following additional information to assist the NRC staff in completing its evaluation of the SCE restart proposal:

1. An assessment of what actions remain to finalize the root cause evaluation for any problems for which only preliminary evaluations have been completed.

2. An assessment of remaining actions to resolve concerns associated with (1) design temperature limitations on the RHR heat exchangers during load rejection events and (2) potential cavitation of CCW pumps following the loss of instrument air to RHR heat exchanger throttle valves.

The licensee subsequently resolved these issues to the staff's satisfaction by completing all root cause evaluations prior to startup, by completing initial calculations demonstrating that the RHR heat exchanger temperature limits are satisfactorily met during load rejection events, and by completing an evaluation which demonstrated the acceptability of CCW pump operation with loss of instrument air for 30 days.

Original signed by G. Knighton for Chares

. rame1, Senior Project Manager Project Directorate V Division of Reactors Projects III, IV, V and Special Projects Office of Nuclear Reactor Regulation

Enclosures:

1. Attendees

2. NRC Agenda

3. SCE Viewgraphs cc: See next page DISTRIBUTION Docket =e NRC & LPDRs JSniezek PD5 Reading GKnighton CTrammel OGC EJordan BRimes AThadani JRichardson FHuay JPartlow FMiraglia TMurley ACRS (10)

MJohnson CGreen

• See previous concurrence DRSP/PD5*

DRSP/D:PD5*

GV CTrammell GKnighton OMartin 5/15/89 5/15/89 5//4/89

Mr. Kenneth P. Baskn San Onofre Nuclear Generating Southern California Edison Company Station, Unit No. 1 cc Mr. Kenneth P. Baskin Vice President Southern California Edison Company 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770 David R. Pigott Orrick, Herrington & Sutcliffe 600 Montgomery Street San Francisco, California 94111 Mr. Robert G. Lacy Manager, Nuclear San Diego Gas & Electric Company P. 0. Box 1831 San Diego, California 92112 Resident Inspector/San Onofre NPS U.S. NRC P. 0. Box 4329 San Clemente, California 92672 Mayor City of San Clemente San Clemente, California 92672 Chairman Board of Supervisors County of San Diego 1600 Pacific Highway Room 335 San Diego, California 92101 Regiunal Administrator, Region V U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 Mr. Paul Szalinski, Chief Radiological Health Branch State Department of Health Services 714 P Street, Office Bldg. #8 Sacramento, California 95814

ENCLOSURE 1 Attendance List May 1, 1989 Meeting NRC SCE C. Trimmell R. frnelas G. W. Knighton M. Medford A. Thadani K. Baskin J. Richardson M. Merlo F. Huey L. Papay J. Partlow D. Nunn F. Miraglia F. Nandy T. Murley R. Ashe-Everest C. Chiu San Diego Gas & Electric R. Lacy

SAN ONOFRE UNIT 1 FULL TERM OPERATING UCENSE CONFIRMATION ACTION LETTER ITEM STATUS Purpose - Develop Status of:

1) FTOL NEEDS

2) THERMAL SHIELD RESOLUTION

3) CAL ITEM STATUS

SAN ONOFRE UNIT I FULL TERM OPERATING UCENSE DISCUSSION ITEMS 7m1 ITES SEP IMS Control Room Habitability SIS Enhancements DCRDR Failure Mode Analysis RCP Trip Quality/Seismic Class. Study R.G. 1.97 Design Basis Precipitation SPDS Steam Generator Overfill Improved CET (ICCI)

PGP Relief/Safety Valve Testing GERIC LITIS OTHE Degraded Grid Relays Open Item - Waterhammer SER ATWAS Steam Generator Tube Inspection (nid-cycle)

TDI Diesel Crankshaft Overloaded 480V - 1E Breakers/Transformer Containment Purge & Vent Thermal Shield Repair Heav Load Handling Steam Generator Plug Problem Rewind Charging Pump Motor (Related to SIS Enhancements)

UCENSEE COWTMMIES

SAN ONOFRE UNIT 1 THERMAL SHIELD

1. Licensee Proposed Actions

2. Staff Positions

3. Licensee Commitments

SAN ONOFRE UNIT 1 STATUS OF CAL ITEMS

1. Discussion and Status of Items

2. Remaining Issues and Schedule

3. Licensee Commitments

SAN ONOFRE UNIT I STATUS OF CAL ITEMS (Discussion and Status of Items)

1. Thermal Shield Issue

2. Potential Single Failure Preventing Auto Load Shed on 480v Swing Bus #3

3. Improper Safety Designation/EQ of Steam Generator Level Instrument (Post-TMI mod)

4. Improper EQ of Charging Pump Motor

5. Wrong Schedule Pipe in RHR System

6. Potential Single Failure -- CCW Valves to RHR Heat Exchangers

7. Potential Overload of 480v Switch-Gear Main Breakers

8. Adequacy of Steam Generator Tube Sleeves

SAFETY OF CONTINUED OPERATION San Onofre Unit 1

1. Review of the AGGREGATE significance of recently identified deficiencies in view of:

Their safety impact and associated root causes Corrective actions taken Programs now in effect which may identify additional deficiencies The potential significance of additional deficiencies identified in the future

2. Principal bases for continued Unit 1 operation without undue risk to health and safety

AGENDA SCE/NRC MEETING OF MAY 1, 1989 SONGS 1 RESTART FOR CYCLE X I.

INTRODUCTION T. MURLEY II.

THERMAL SHIELD REVIEW STATUS NRC III.

SCE OPENING REMARKS L T. PAPAY IV.

PROPOSED FUTURE OPERATION K P. BASKIN V.

CYCLE X OPERATION M. O. MEDFORD VI.

CYCLE XI AND XII MODIFICATIONS M. O. MEDFORD VII.

NRC ACTIONS NEEDED R. ORNELAS VIII.

CONFIRMATORY ACTION LETTER M. L. MERLO SCE RESPONSE

III, SCE OPENING REMARKS 1

g~

IV, PROPOSED FUTURE OPERATION MEETING OBJECTIVES o

PROVIDE AN UNDERSTANDING OF THE HISTORY AND STATUS OF SONGS 1 o

PROVIDE A DESCRIPTION OF THE MODIFICATIONS AND THE HIGH LEVEL OF EXPENDITURE ALREADY COMMITTED TO SONGS 1 o

PROVIDE AN UNDERSTANDING OF SCE DESIRE FOR CONTINUED OPERATION OF SONGS 1 THROUGH ITS LICENSED LIFETIME IF ECONOMICALLY FEASIBLE o

PROVIDE A PLAN FOR CYCLE X OPERATION INCLUDING A MIDCYCLE OUTAGE FOR INSPECTION AND, IF NEEDED, REPAIR OF THERMAL SHIELD o

PROVIDE A PLAN FOR ACCELERATED COMPLETION OF NRC OPEN ITEMS o

PROVIDE A DESCRIPTION OF NEEDED NRC ACTION o

ADDRESS THE ISSUES RAISED BY THE CONFIRMATORY ACTION LETTER 2

IV, PROPOSED FUTURE OPERATION BACKGROUND o

SONGS 1 DESIGN EARLY 1960's o

LICENSED POWER RATING 1347 MWt o

THREE LOOP WESTINGHOUSE NSSS o

BECHTEL POWER BALANCE OF PLANT o

TURNKEY PLANT o

AEC APPLICATION FILED FEBRUARY 1, 1963 o

AEC CONSTRUCTION PERMIT MARCH 2, 1964 o

AEC PROVISIONAL OPERATING LICENSE MARCH 27, 1967 o

COMMERCIAL OPERATION JANUARY 1, 1968 o

STANDBY POWER ADDITION/SPHERE ENCLOSURE BUILDING 1976 - 1977 o

SYSTEMATIC EVALUATION PROGRAM 1977 - PRESENT o

STEAM GENERATOR SLEEVING 1980- 1981 o

SEISMIC UPGRADES 1982-1984 o

INTEGRATED IMPLEMENTATION SCHEDULE 1983 - PRESENT o

WATER HAMMER 1985 3

IV. PROPOSED FUTURE OPERATION MAJOR MODIFICATIONS o

SPHERE ENCLOSURE BUILDING o

STANDBY POWER ADDITION o

STEAM GENERATOR SLEEVING o

SECURITY IMPROVEMENTS o

TMI MODIFICATIONS o

SEISMIC UPGRADE TO 0.67g EARTHQUAKE o

ENVIRONMENTAL QUALIFICATION MODIFICATIONS o

APPENDIX R (FIRE PROTECTION) o WATER HAMMER 4

IV. PROPOSED FUTURE OPERATION EXPENDITURES o

SONGS 1 CAPITAL EXPENDITURES BY CYCLE o

SONGS 1 CUMULATIVE CAPITAL EXPENDITURES o

INDUSTRY COMPARISON OF TOTAL CAPITAL EXPENDITURES THROUGH 1987 o

INDUSTRY COMPARISON OF CAPITAL EXPENDITURES FOR FIVE YEARS (1983 THROUGH 1987) 5

SONGS 1 Capital Expenditures by Cycle

$216 200

.o..

U..r.d 1$160 0

100-prd

$P-8

$177$

$26

$220 Fiore 644

$68F

- Seimi

$1163 EO2- $16NS 1

Initia EOs 1-

$9 9

Fie0 Drwng-$3crtctolOe 2

SONGS 1 Cumulative Capital Expenditures 800 3rd Aux. Feedwater Pump, NI Electrical Equipment Qualificati 600M Fire Protection. Seismic Upgrades, Electrical Equipment ualification 600-Seismic Upgrades, Drawing Verification, Electrical Equipment Qualification TMI Mods, Fire Protection Steam Generator Sleeving, TMI Mods Sphere Enclosure Building, 200 Standby Power Addition Initial Cost 0

68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 Year

9 Year of Expense Dollars (Millions)

Big Rock Point Yankee Rowe Em Point Beach 1&2 Vermont Yankee v

Connecticut Yankee Ginna Maine Yankee Millstone 1 Monticello Palisades Robinson 2 Nine Mile Point Oyster Creek SONGS 1 Pilgrim

Capital Expenditure Comparison 1983 through 1987 500

$412 400-$8

$30 300 200 00

$15 0

5z a

P 432

IV. PROPOSED FUTURE OPERATION INTEGRATED IMPLEMENTATION SCHEDULE (IIS) o DEVELOPED TO PROVIDE STABILITY AND PREDICTABILITY TO IMPLEMENTATION OF CAPITAL MODIFICATIONS o

PROJECTS WITH HIGHEST SAFETY SIGNIFICANCE IMPLEMENTED FIRST o

PROJECTS WITH LOW SAFETY SIGNIFICANCE COULD BE DEFERRED o

NOT INTENDED TO RESOLVE ALL OPEN ISSUES WITHIN A LIMITED TIME FRAME o

THE IIS WAS USED TO OBTAIN PUC APPROVAL FOR RECOVERY OF MODIFICATION EXPENDITURE o

THE IIS WAS APPROVED BY LICENSE AMENDMENT DATED APRIL 28, 1987 o

PROCESS FOR MAINTAINING ECONOMIC VIABILITY OF SONGS 1 10

IIS EXPERIENCE PROJECTS PROJECTS COMPLETED CYCLE ORIGINALLY SCHEDULED ORIGINAL ADDITIONAL TOTAL IX 10 7

5 12 X

4 3

16 19 XI 4

(TWO PROJECTS ALREADY COMPLETED, ONE CANCELLED) 11

HS (CONTINUED) o EVALUATION

- IS HAS NOT ACHIEVED DESIRED RESULTS

- NRC PERSPECTIVE - TOO MANY OPEN ITEMS REMAIN

- SCE PERSPECTIVE - CAPITAL EXPENDITURES NOT SATISFACTORILY CONTROLLED o

FUTURE PLANS

- IMPROVE COMMUNICATIONS AND DOCUMENTATION OF REVISIONS

- REESTABLISH CONTROL OF EXPENDITURES (APPROXIMATELY $30 MILLION PER CYCLE) 12

0 0

V. SAN ONOFRE UNIT 1 CYCLE X OPERATION o

JUNE 1990 MIDCYCLE OUTAGE THERMAL SHIELD INSPECTION STEAM GENERATOR INSPECTION CASE 1 - THERMAL SHIELD CONDITION DEMONSTRATED ACCEPTABLE o

STARTUP AFTER 40 DAY OUTAGE o

EARLY 1991 SHUTDOWN CYCLE XI REFUELING THERMAL SHIELD REPAIR REACTOR VESSEL 10 YEAR ISI CYCLE XI MODIFICATIONS CASE 2 - THERMAL SHIELD CONDITION NOT DEMONSTRATED ACCEPTABLE o

EXTENDED MIDCYCLE OUTAGE THERMAL SHIELD REPAIR REACTOR VESSEL 10 YEAR ISI CYCLE XI MODIFICATIONS o

STARTUP AFTER 220 DAY EXTENDED OUTAGE o

MID 1991 SHUTDOWN CYCLE XI REFUELING ACTIVITIES ONLY 13

VI. CYCLE XI AND XII MODIFICATIONS PROGRAM TO ACCELERATE MODIFICATIONS o

IDENTIFIED ALL FEASIBLE MODIFICATIONS FOR CYCLE XI o

REVIEWED FINANCIAL CONSTRAINTS o

ELIMINATED AS MANY OPEN ITEMS AS POSSIBLE o

RESULTED IN TRANSFER OF SIS MODIFICATIONS FROM CYCLE XI TO CYCLE XII o

ALL OTHER FEASIBLE MODIFICATIONS COMPLETED BY CYCLE XI (INCLUDING SOME ORIGINALLY SCHEDULED FOR CYCLE XII) 14

VI, CYCLE XI AND XII MODIFICATIONS CYCLE XI o

3 ITEMS FROM CYCLE XI OF IIS o

1 ITEM FOR CYCLE XI RESOLVED BY ANALYSIS o

2 ITEMS FROM CYCLE XII OF IIS o

9 NEW REGULATORY ITEMS o

10 PLANT BETTERMENT ITEMS CYCLE XII o

1 ITEM FROM CYCLE XI OF IIS o

7 ITEMS FROM CYCLE XII OF IIS o

1 ITEM FROM CYCLE XIII of IIS 15

NRC OPEN ITEM LIST FOLLOWING CYCLE XI MODIFICATIONS TMI ITEMS (8 TOTAL) o 4 COMPLETED o

2 EVALUATIONS SUBMITED/MODIFICATIONS SCHEDULED o

2 SCHEDULED FOR CYCLE XII MULTI-PLANT ACTION ITEMS (5 TOTAL) o 3 COMPLETED o

1 EVALUATION COMPLETED/MODIFICATION SCHEDULED (IF REQUIRED) o 1 SCHEDULED FOR CYCLE XII SYSTEMATIC EVALUATION PROGRAM ITEMS (5 TOTAL) o 2 COMPLETED o

1 EVALUATION SUBMITED/MODIFICATIONS SCHEDULED o

1 UNRESOLVED SAFETY ISSUE REVIEW o

1 SCHEDULED FOR CYCLE XII OTHER ITEMS (6 TOTAL) o 6 COMPLETED 16

VII. NRC ACTION NEEDED o

RESTART FOR CYCLE X NIS AMENDMENT THERMAL SHIELD AMENDMENT RESTART APPROVAL (CONFIRMATORY ACTION LETTER) o CYCLE X MIDCYCLE OUTAGE STEAM GENERATOR SURVEILLANCE TECHNICAL.

SPECIFICATION CHANGE THERMAL SHIELD INSPECTION ACCEPTANCE CRITERIA o

CYCLE XI NONE o

CYCLE XII CONTROL ROOM HABITABILITY SIS ENHANCEMEiS-.

o OTHER ADEQUACY OF STATION VOLTAGES CONTAINMENT PURGE AND VENT TECHNICAL SPECIFICATIONS

~~DI CRANX~i EMBRITTLEMENT OF REACTOR VESSEL SUPPORTS RPS/ESF RESPONSE TIME TECHNICAL SPECIFICATIONS LOAD COMBINATION ANALYSIS (CONTAINMENT)

TORNADO PROTECTION SEP GROUND WATER 17

0 VIII.

CONFIRMATORY ACTION LETTER SCE RESPONSE

SONGS UNIT 1 RE-START REPORT o

OVERVIEW o

TECHNICAL ISSUES o

ADEQUACY OF PROGRAMMATIC CORRECTIVE ACTIONS o

OVERALL SAFETY SIGNIFICANCE o

CONCLUSIONS SONGS 1 RE-START REPORT OVERVIEW o

OCTOBER 1988 REORGANIZATION o

NRC LETTER OF FEBRUARY 8 7 TECHNICAL ISSUES SGi TUBE PLUGGING ADDRESSED SEPARATELY o

SCE RESPONSE DEVELOPMENT MANAGEMENT PARTICIPATION REVIEW OF ALL DEFICIENCIES SINCE AUGUST 1988 VALIDATION o

RESPONSE APPROACH REVIEW SAFETY SIGNIFICANCE/PROBABILITY, CORRECTIVE ACTION, ROOT CAUSE OF EACH ISSUE REVIEW PROBABILITY OF FINDING SIMILAR ITEMS REVIEW ADEQUACY OF PREVIOUS CORRECTIVE ACTIONS UNIQUE ASPECTS OF SONGS 1 DESIGN o

DESIGNED AND BUILT IN MIDDLE 1960s TURN-KEY PLANT PRECEDED MODERN CRITERIA AND STANDARDIZATION o

SONGS 1 DESIGN CONCEPTS COMPONENT LEVEL REDUNDANCY OPERATIONAL FLEXIBILITY o

STANDARD PLANT DESIGN CONCEPTS TRAIN LEVEL REDUNDANCY SEPARATION TECHNICAL ISSUES o

12 ISSUES ADDRESSED IN RE-START REPORT 6 ADDRESSED IN NRC LETTER 6 ADDED BY SCE REVIEW 2 IDENTIFIED SUBSEQUENT TO REPORT ALL SCE IDENTIFIED o

7 ISSUES SPECIFICALLY RELATED TO LICENSE AMENDMENTS o

OTHER 7 ISSUES DISCUSSED WITH NRC STAFF 7>.e OVERALL SAFETY SIGNIFICANCE o

EXISTING ISSUES OF LOW SAFETY SIGNIFICANCE COMPLETION OF SAFETY FUNCTION WITHOUT MODIFICATION OPERATOR ACTION TO MITIGATE EVENT ALTERNATE MITIGATION METHODS AVAILABLE LOW PROBABILITY OF OCCURRENCE BASED ON PRA o

NECESSARY MODIFICATIONS HAVE BEEN COMPLETED PRIOR TO RE-START 7 ITEMS HAVE BEEN PERMANENTLY CORRECTED BY PHYSICAL 4 ITEMS CORRECTED VIA ANALYSIS OR TECH SPEC CHANGES 3 INTERIM FIXES ADEQUACY OF PROGRAMMATIC AND CORRECTIVE ACTIONS o

COMMON ROOT CAUSES OF TECHNICAL ISSUES EXCESSIVE RELIANCE ON CONTRACTORS INEXPERIENCED DESIGN STAFF CHANGING DOCUMENTATION STANDARDS COMMITMENT TRACKING SYSTEM POST-MODIFICATION TESTING o

ROOT CAUSES CONSISTENT WITH 1988 LETTER o

COURSE CORRECTIONS CHANGES TO DBD SCHEDULE AND INPUTS RE-PERFORM ECCS 1976 SINGLE FAILURE ANALYSIS EVALUATE CAUSE OF POST-MODIFICATION TESTING WEAKNESS IDENTIFICATION OF FUTURE ISSUES o

MECHANISMS OF FUTURE ISSUES CONTINUED EMPHASIS ON ENGINEERING EVALUATIONS INCREASED EXPERIENCE OF DESIGN STAFF INCREASED INVOLVEMENT BY ENGINEERING PERSONNEL RE-PERFORMANCE OF SINGLE FAILURE ANALYSES DESIGN BASES DOCUMENTATION EFFORT o

SAFETY SIGNIFICANCE LOW SIGNIFICANCE OF ISSUES IDENTIFIED TO DATE UNIQUE DESIGN OF SONGS 1 DEFENSE IN-DEPTH APPROACH TO PLANT DESIGN AND OPERATION EXISTENCE OF DVERSE AND REDUNDANT EQUIPMENT INCREASING SOPHISTICATION OF SAFETY ANALYSIS TECHNIQUES CONCLUSIONS o

CAUSES OF TECHNICAL ISSUES UNIQUE ASPECTS OF OLDER DESIGN PREVIOUS PROGRAMMATIC DEFICIENCIES o

SAFETY SIGNIFICANCE DETERMINED TO BE LOW EXISTING ISSUES OF LOW SAFETY SIGNIFICANCE

-NEW ISSUES EXPECTED TO BE OF SIMILAR LOW SAFETY SIGNIFICANCE o

PREVIOUSLY INITIATED CORRECTIVE ACTIONS CONTRIBUTED TO IDENTIFICATION AND CORRECTION OF TECHNICAL ISSUES EFFECTIVE IN ADDRESSING ROOT CAUSES SOME COURSE CORRECTIONS NEEDED o

SONGS 1 OPERATION CAN CONTINUE WITHOUT UNDUE RISK TO THE HEALTH AND SAFETY OF THE PUBLIC