NUREG-1218, Disapproves 900320 Response to Generic Ltr 89-19 Re Safety Implications of Control Sys in LWRs
| ML13302B346 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/30/1990 |
| From: | Larkins J Office of Nuclear Reactor Regulation |
| To: | Cotton G, Ray H Southern California Edison Co |
| References | |
| GL-89-019, REF-GTECI-A-47, REF-GTECI-SY, RTR-NUREG-1218, TAC-74994, TAC-74995, TASK-A-47, TASK-OR NUDOCS 9009060071 | |
| Download: ML13302B346 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 August 30, 1990 Docket Nos. 50-361 and 50-362 Mr. Harold B. Ray Mr. Gary D Cotton Senior Vice President Senior Vice President Southern California Edison Co.
Engineering and Operations Irvine Operations Center San Diego Gas & Electric Co.
23 Parker Street 101 Ash Street Irvine, California 92718 San Diego, California 92112 Gentlemen:
SUBJECT:
SOUTHERN CALIFORNIA EDISON COMPANY'S RESPONSE TO GENERIC LETTER 89-19 REGARDING SAFETY IMPLICATIONS OF CONTROL SYSTEMS IN LWR NUCLEAR POWER PLANTS (TAC NOS. 74994 AND 74995)
By letter dated March 20, 1990, Southern California Edison Company responded to Generic Letter 89-19, "Request for Action Related to Resolution of Unresolved Safety Issue A-47, 'Safety Implication of Control Systems in LWR Nuclear Power Plants' Pursuant to 10 CFR 50.54(f)." In your letter, you stated that more detailed design studies and safety assessments must be completed before a decision can be made regarding implementation of a steam generator overfill protection system (SGOPS) at San Onofre Nuclear Generating Station, Unit Nos. 2 and 3. This conclusion is based upon inherent plant-specific differences and the implementation of SGOPS may increase the probability of loss of feedwater events due to inadvertent SGOPS actuation. Moreover, your letter stated that the appropriate framework to evaluate steam generator overfill events and the safety impact of implementing a steam generator overfill protection system is the Individual Plant Examination (IPE).
We do not agree with your position that a more detailed design and safety assessment using the IPE is an appropriate framework to continue the evaluation of steam generator overfill safety impacts. Previous NRC analyses performed to evaluate alternatives to resolve USI A-47, "Safety Implications of Control Systems," provided insight with respect to the safety benefits, impacts, and costs of modifications for overfill protection. Plant specific differences were considered in the development of NUREG-1218, "Regulatory Analysis for Resolution of USI A-47," and in the preparation of the Generic Letter 89-19.
You had ample opportunity to provide comments on this issue when the Federal Register notice was published in May 1989.
Combustion Engineering (CE) plants, as a class, do not provide steam generator overfill protection. Overfill events have occurred at CE plants and other light water reactors. The consequences resulting from such events depend largely on piping system integrity, are difficult to model accurately, and have large uncertainties. It is for these reasons that IPE evaluation will not add significant information to close this issue. Further, we believe that the AroCct..
Messrs. Ray and Cotton August 30, 1990 potential negative impacts of inadvertent isolation of feedwater can be made insignificant through sound design, with reliable equipment, and with implementation of a reasonable test strategy.
In regard to the implementation schedule for San Onofre Nuclear Generating Station, Unit Nos. 2 and 3, the staff is of the opinion that implementation of the SGOPS prior to the startup following the Cycle 6 refueling outage is feasible. We request your response within 45 days from receipt of this letter.
Sincerely, original signed by Charles M. Trammell John T. Larkins, Acting Project Director Project Directorate V Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation cc:
See next page DISTRIBUTION Docket File L. Kokajko A. Thadani D. Matthews NRC & Local PDR OGC-Rockville S. Rhow J. Mauck PD5 Reading E. Jordan K. Jabbour C. Caldwell D. Crutchfield S. Newberry A. Hon P. Johnson B. Boger ACRS (10)
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OFFICIAL RECORD COPY t) Ddcument Name:
PDV DISTRIBUTION
Messrs. Ray and Cotton San Onofre Nuclear Generating Southern California Edison Company Station, Unit Nos. 2 and 3 cc:
Charles R. Kocher, Esq.
Mr. Richard J. Kosiba, Project Manager James A. Beoletto, Esq.
Bechtel Power Corporation Southern California Edison Company 12440 E. Imperial Highway Irvine Operations Center Norwalk, California 90650 23 Parker Irvine, California 92718 Mr. Robert G. Lacy Manager, Nuclear Department Orrick, Herrington & Sutcliffe San Diego Gas & Electric Company ATTN: David R. Pigott,.Esq.
P. 0. Box 1831 600 Montgomery Street San Diego, California 92112 San Francisco, California 94111 Mr. John Hickman Alan R. Watts, Esq.
Senior Health Physicist Rourke & Woodruff Environmental Radioactive Mgmt. Unit 701 S. Parker St. No. 7000 Environmental Management Branch Orange, California 92668-4702 State Department of Health Services 714 P Street, Room 616 Mr. Sherwin Harris Sacramento, California 95814 Resource Project Manager Public Utilities Department Resident Inspector, San Onofre NPS City of Riverside do U.S. Nuclear Regulatory Commission 3900 Main Street Post Office Box 4329 Riverside, California 92522 San Clemente, California 92672 Mr. Charles B. Brinkman Mayor Combustion Engineering, Inc.
City of San Clemente 12300 Twinbrook Parkway, Suite 330 San Clemente, California 92672 Rockville, Maryland, 20852 Regional Administrator, Region V Mr. Phil Johnson U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Region V Walnut Creek, California 94596 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 Chairman, Board of Supervisors San Diego County Mr. Don Womeldorf 1600 Pacific Highway, Room 335 Chief, Environmental Management Branch San Diego, California 92101 California Department of Health 714 P Street, Room 616 Sacramento, California 95814 (14)