ML021420220

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SONGS, Units 2 & 3-(MB4508/4509) Issuance of Amds 188 & 179- Reactor Protection System and Engineered Safety Features Actuation System Sensor Response Time Testing
ML021420220
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 05/22/2002
From: Wang A
NRC/NRR/DLPM
To: Ray H
Southern California Edison Co
References
TAC MB4508, TAC MB4509
Download: ML021420220 (16)


Text

May 22, 2002 Mr. Harold B. Ray Executive Vice President Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 -

ISSUANCE OF AMENDMENTS RE: REACTOR PROTECTION SYSTEM AND ENGINEERED SAFETY FEATURES ACTUATION SYSTEM SENSOR RESPONSE TIME TESTING (TAC NOS. MB4508 AND MB4509)

Dear Mr. Ray:

The Commission has issued the enclosed Amendment No. 188 to Facility Operating License No. NPF-10 and Amendment No.179 to Facility Operating License No. NPF-15 for San Onofre Nuclear Generating Station, Units 2 and 3, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated March 11, 2002.

The amendments revise TS Section 1.1, Definitions, to change the definition of response time testing as it is applied to the Engineered Safety Features, and the Reactor Protective System.

The proposed change is based on approved Technical Specification Task Force (TSTF)

Traveler TSTF-368, Revision 0, Incorporate Combustion Engineering Owners Group (CEOG)

Topical Report to Eliminate Pressure Sensor Response Time Testing.

A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

/RA/

Alan Wang, Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362

Enclosures:

1. Amendment No. 188 to NPF-10
2. Amendment No. 179 to NPF-15
3. Safety Evaluation cc w/encls: See next page

May 22, 2002 Mr. Harold B. Ray Executive Vice President Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 -

ISSUANCE OF AMENDMENTS RE: REACTOR PROTECTION SYSTEM AND ENGINEERED SAFETY FEATURES ACTUATION SYSTEM SENSOR RESPONSE TIME TESTING (TAC NOS. MB4508 AND MB4509)

Dear Mr. Ray:

The Commission has issued the enclosed Amendment No. 188 to Facility Operating License No. NPF-10 and Amendment No. 179 to Facility Operating License No. NPF-15 for San Onofre Nuclear Generating Station, Units 2 and 3, respectively. The amendments consist of changes to the Technical Specifications (TSs) in response to your application dated March 11, 2002.

The amendments revise TS Section 1.1, Definitions, to change the definition of response time testing as it is applied to the Engineered Safety Features, and the Reactor Protective System.

The proposed change is based on approved Technical Specification Task Force (TSTF)

Traveler TSTF-368, Revision 0, Incorporate Combustion Engineering Owners Group (CEOG)

Topical Report to Eliminate Pressure Sensor Response Time Testing.

A copy of our related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

/RA/

Alan Wang, Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362

Enclosures:

1. Amendment No. 188 to NPF-10
2. Amendment No. 179 to NPF-15
3. Safety Evaluation cc w/encls: See next page DISTRIBUTION PUBLIC PDIV-2 r/f G. Hill (4) RidsNrrDlpmLpdiv (L. Barnett)

RidsNrrPMAWang RidsNrrLAMMcAllister RidsNrrDripRorp (R.Dennig) RidsAcrsAcnwMailCenter RidsOgcRp RidsRgn4MailCenter (C. Johnson, L. Hurley, D. Bujol) NRR-100 RTjader TS: (188) ML021430017 TS: (179) ML021430010 ACCESSION NO: ML021420220 PKG: ML021420260 NRR-058 OFFICE PDIV-2/PM PDIV-1/LA EEIB* OGC PDIV-2/SC NAME AWang MMcAllister ECMarinos RHoefling SDembek DATE 4/11/02 4/10/02 03/28/02 4/22/02 4/26/02 OFFICIAL RECORD COPY DOCUMENT NAME: C:\ADAMS\Cache\ML0214202200.wpd

SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS AND ELECTRIC COMPANY THE CITY OF RIVERSIDE, CALIFORNIA THE CITY OF ANAHEIM, CALIFORNIA DOCKET NO. 50-361 SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No.188 License No. NPF-10

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Southern California Edison Company, et al.

(SCE or the licensee), dated March 11, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Facility Operating License No. NPF-10 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 188, are hereby incorporated in the license. Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Stephen Dembek, Chief, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: May 22, 2002

ATTACHMENT TO LICENSE AMENDMENT NO. 188 FACILITY OPERATING LICENSE NO. NPF-10 DOCKET NO. 50-361 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 1.1-3 1.1-3 1.1-4 1.1-4 1.1-5 1.1-5

  • 1.1-6 *1.1-6 B 3.3-37 B 3.3-37 B 3.3-37a B 3.3-37a B 3.3-103a B 3.3-103a
  • B 3.3-103b *B 3.3-103b B 3.3-103c B 3.3-103c
  • Overleaf pages provided to maintain document completeness. No changes on these pages.

SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS AND ELECTRIC COMPANY THE CITY OF RIVERSIDE, CALIFORNIA THE CITY OF ANAHEIM, CALIFORNIA DOCKET NO. 50-362 SAN ONOFRE NUCLEAR GENERATING STATION, UNIT 3 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No.179 License No. NPF-15

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Southern California Edison Company, et al.

(SCE or the licensee) dated March 11, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Facility Operating License No. NPF-15 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B, as revised through Amendment No. 179, are hereby incorporated in the license. Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Stephen Dembek, Chief, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: May 22, 2002

ATTACHMENT TO LICENSE AMENDMENT NO. 179 FACILITY OPERATING LICENSE NO. NPF-15 DOCKET NO. 50-362 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 1.1-3 1.1-3 1.1-4 1.1-4 1.1-5 1.1-5

  • 1.1-6 *1.1-6 B 3.3-37 B 3.3-37 B 3.3-37a B 3.3-37a B 3.3-103a B 3.3-103a
  • B 3.3-103b *B 3.3-103b B 3.3-103c B 3.3-103c
  • Overleaf pages provided to maintain document completeness. No changes on these pages.

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 188 TO FACILITY OPERATING LICENSE NO. NPF-10 AND AMENDMENT NO. 179 TO FACILITY OPERATING LICENSE NO. NPF-15 SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS AND ELECTRIC COMPANY THE CITY OF RIVERSIDE, CALIFORNIA THE CITY OF ANAHEIM, CALIFORNIA SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 DOCKET NOS. 50-361 AND 50-362

1.0 INTRODUCTION

By application dated March 11, 2002, Southern California Edison Company, et al. (the licensee), requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS), Units 2 and 3. The proposed amendment would revise TS Section 1.1, Definitions, to change the definition of response time testing as it is applied to the Engineered Safety Features (ESF), and the Reactor Protective System (RPS). The proposed change is based on approved Technical Specification Task Force (TSTF) Traveler TSTF-368, Revision 0, Incorporate Combustion Engineering Owners Group (CEOG) Topical Report to Eliminate Pressure Sensor Response Time Testing.

The amendment will allow either an allocated sensor response time or a measured sensor response time for the identified ESF Actuation System (ESFAS) and RPS pressure sensors when performing response time testing (RTT).

2.0 BACKGROUND

The requirement for periodic testing of reactor trip systems is established in Section 10 CFR 50.55a, Codes and standards. Section 50.55a(h)(2), "Protection systems," states the following: For nuclear power plants with construction permits issued after January 1, 1971, but before May 13, 1999, protection systems must meet the requirements stated in either IEEE

[Institute of Electrical and Electronics Engineers] [Standard] 279, Criteria for Protection Systems for Nuclear Power Generating Stations, or IEEE [Sandard] 603-1991, Criteria for Safety Systems for Nuclear Power Generating Stations, and the correction sheet dated January 30, 1995. For nuclear power plants with construction permits issued before January 1, 1971, protection systems must be consistent with their licensing basis or may meet the requirements of IEEE [Standard] 603-1991 and the correction sheet dated January 30,1995.

In addition, Section 10 CFR 50.36(c)(2)(ii)(A) requires establishment of a TS limiting condition for operation for Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

Section 50.36(c)(3) also states that Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

Because the times for equipment operation in an accident analysis are the summation of all response times of components within the protective function, a value for the sensor response time must be included. The sensor response time can be an actual measured value or it can be an assumed value that is allocated to the sensor based on NRC-approved methodology.

Combustion Engineering Owners Group (CEOG) topical report (TR) CE [Combustion Engineering] NPSD-1167, Elimination of Pressure Sensor Response Time Testing Requirements, Revision 2, is such a methodology.

In letters dated May 12 and June 6, 2000, the CEOG submitted CE NPSD-1167, Revision 2, which proposed eliminating the requirements for RTT of selected pressure sensors in the RPS and ESFASs (i.e., the emergency core cooling system and the isolation actuation system), and incorporated NRC and utility comments on Revision 1 and corrected Appendices A and C. The methodology in Revision 2 is that the sensor response time is derived from the original manufacturer or from a statistical analysis of the results of previous RTTs, where the statistical analysis is sufficiently conservative to ensure that the allocated response time assigned to the sensor will be valid for 95 percent of the population with a 95 percent confidence level.

The TR modifies pressure transmitter allocated response times from values that were based on historical data collected at plants to values that are based on vendor data of expected response times of properly operating instruments. The TR includes plant-specific information from 5 licensees with a total of 11 nuclear power plants including SONGS, Units 2 and 3. The following are the pressure sensors for which the CEOG requested elimination of RTT:

  • Rosemount Differential Pressure or Pressure Transmitters Model 1152 DP, HP, AP, and GP, range codes 3, 4, 5, 6, 7, 8, 9, and 0.
  • Rosemount 1153 Differential Pressure or Pressure Transmitters Models 1153 D, H, A, and G, range codes 3, 4, 5, 6, 7, 8, and 9.
  • Rosemount 1154 Differential Pressure or Pressure Transmitters Models DP, HP, and GP, range codes 4, 5, 6, 7, 8, 9, and 0.
  • Rosemount 1154H Differential Pressure or Pressure Transmitters Models D, H, and S, range codes 4, 5, 6, 7, 8, and 9.
  • Barton 763 and 763A Pressure Transmitter and 764 Differential Pressure Transmitter.
  • Foxboro Models N-E11DM, N-E13DM, and E13DM.
  • Weed Model N-E11GM.

The table below contains a list of transmitters proposed by the licensee to utilize allocated response times. The use of allocated response times in these applications is considered to be acceptable as long as the components and methodology for verification have been previously reviewed and approved by the NRC.

TABLE Instrument Make / Model Allocated Response Time RCS Low Flow Rosemount Model 1153 0.200 second Range Code 6 Containment Pressure Foxboro Model N-E11 0.430 second DM SG Level Weed Model N-E13 DM 0.520 second Pressurizer Pressure Rosemount Model 1154, 0.200 second Range Code 9 Weed Model N-E11 GM 0.135 second RWT Level Foxboro Model E13 DM 0.610 second SG Pressure (RPS and Weed Model N-E11 GM 0.135 second ASGT*)

  • Asymmetric Steam Generator Transient The TR includes the following recommendations for actions to ensure sensors are operating correctly and that calibration or other surveillance will provide an accurate indication that the dynamic characteristics of the instrument will be accurately reflected in a static calibration.
1. Perform a hydraulic RTT prior to installation of a new transmitter/switch or following refurbishment of the transmitter/switch (e.g., sensor cell or variable damping components) to determine an initial sensor-specific response time value. The power interrupt test is an alternate method to use on force-balance transmitters; the purpose of this test is to verify sensor response time is within the limits of the allocated value for the transmitter function.
2. For transmitters and switches that use capillary tubes, RTT should be performed after initial installation and after any maintenance or modification activity that could damage the capillary tubes.
3. Perform periodic drift monitoring on all Rosemount pressure and differential pressure transmitters, models 1151, 1152, 1153, and 1154. Guidance on drift monitoring can be found in EPRI [Electric Power Research Institute] NP-7121 and Rosemount Technical Bulletins. Drift monitoring intervals should be based on utility response to NRC Bulletin 90-01, Loss of Fill-Oil in Transmitters Manufactured by Rosemount.
4. If variable damping is used, implement a method to ensure that the potentiometer is at the required setting and cannot be inadvertently changed.

This approach should eliminate the need for RTT to detect a variable damping

failure mode. Otherwise, RTT each transmitter by hydraulic or electronic white noise analysis methods, at a minimum, following each transmitter calibration.

In letter dated December 5, 2000, the NRC staff issued its Safety Evaluation (SE) on CE NPSD-1167, Revision 2. In that SE, the NRC staff stated (1) that, based on Revision 2 of the TR and its recommendations, RTT is not required for sensors and systems specified in the report to demonstrate satisfactory sensor performance, and that other routine surveillance, such as calibrations and drift monitoring, are sufficient to demonstrate satisfactory sensor performance; and (2) that Revision 2 to CE NPSD-1167, as modified by the CEOG letter dated June 6, 2000, is acceptable as a basis for eliminating RTT from TSs for the sensors and systems identified in the report.

An acceptable set of TSs to implement the elimination of RTT based on Revision 2 of CE NPSD-1167 is given in NRC/Nuclear Energy Institute (NEI) TS TSTF-368, which was approved by the NRC in its letter to NEI dated January 25, 2001. TSTF-368 approves changes to the improved Standard Technical Specifications, NUREG-1432, Standard Technical Specifications Combustion Engineering, Revision 1, dated April 1995, based on CE NPSD-1167.

3.0 EVALUATION The amendments would revise the definition of RTT as it is applied to the ESF, and the ESFAS.

Specifically, TS Section 1.1, Definitions, would be revised as follows.

The definition for ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME currently reads:

The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

This definition would be appended with the following:

In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

The definition for REACTOR PROTECTIVE SYSTEM (RPS) RESPONSE TIME currently reads:

The RPS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RPS trip setpoint at the channel sensor until electrical power to the CEAs [control element assemblies] drive mechanism is interrupted. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured.

This definition would be appended with the following:

In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC.

In summary, the proposed change would allow either an allocated or a measured response time to be utilized for selected sensors in the ESF and ESFAS instrument loops.

Additionally, the licensee proposed to revise the applicable TS Bases to clarify the provision to verify response times in lieu of measuring them. The CEOG TR will also be explicitly referenced in the revised section of the TS Bases.

In its application, the licensee addressed the recommendations listed above. The licensees responses to the recommendations are given below:

1. Perform a hydraulic RTT prior to installation of a new transmitter/switch or following refurbishment of the transmitter/switch (e.g., sensor cell or variable damping components) to determine an initial sensor-specific response time value. The power interrupt test is an alternate method to use on force-balance transmitters; the purpose of this test is to verify sensor response time is within the limits of the allocated value for the transmitter function.

SCE Response: SONGS 2 & 3 performs pre-installation RTT. This testing is performed under procedures SO23-II-3.1,3.2,3.3, and 3.4; Surveillance Requirement for Plant Protection System Response Time Test for Channel A, Channel B, Channel C, and Channel D, respectively. The test utilizes a hydraulic ramp generator and a Teledyne reference transducer. A ramp test is performed in the direction of use (i.e., from high to low pressure for a low trip and low to high for a high trip.)

2. For transmitters and switches that use capillary tubes, RTT should be performed after initial installation and after any maintenance of modification activity that could damage the capillary tubes.

SCE Response: The SONGS 2 & 3 configuration does not include any Rosemount transmitters with capillary tubes in these RPS or ESF system applications. All of the pressure transmitters in these applications are connected to the process piping using l/2 inch OD SS316 tubing.

3. Perform periodic drift monitoring on all Rosemount pressure and differential pressure transmitters, models 1151, 1152, 1153, and 1154. Guidance on drift monitoring can be found in EPRI NP-7121 and Rosemount Technical Bulletins.

Drift monitoring intervals should be based on utility response to NRC Bulletin 90-01.

SCE Response: On March 9, 1990 the NRC issued NRC Bulletin 90-01, Loss of Fill-Oil in Transmitters Manufactured by Rosemount, and on December 22, 1992 issued Supplement 1 to this bulletin. SCE provided responses to the NRC detailing the actions being taken in response to the bulletin in letters dated July 19, 1990, March 4, 1993, and February 11, 1994, respectively. SCE will

continue to comply with the actions requested by the NRC, including periodic drift monitoring, for Rosemount Model 1153 Series B and D, the Model 1154 transmitters manufactured prior to July 11, 1989 except for the monitoring frequency of category 1b transmitters which may exceed the 24 month monitoring frequency limit provided in the Bulletin (SONGS 2 & 3 operate on a 24 month refueling cycle). By letter and safety evaluation dated April 12, 1995, the NRC staff found the SCE responses to Bulletin 90-01 Supplement 1, to be acceptable.

4. If variable damping is used, implement a method to ensure that the potentiometer is at the required setting and cannot be inadvertently changed.

This approach should eliminate the need for RTT to detect a variable damping failure mode. Otherwise, RTT each transmitter by hydraulic or electronic white noise analysis methods, at a minimum, following each transmitter calibration.

SCE Response: The SONGS 2 & 3 configuration does not include any RPS/ESF transmitters with the variable damping feature.

Based on its review of the licensee's responses to the above recommendations, the NRC staff concludes that the licensee has acceptably addressed the recommendations.

The NRC staff also reviewed the licensees proposed changes to the Bases of the TSs. The proposed changes to the Bases shown in the application are consistent with the NRC staffs SE for CE NPSD-1167, Revision 2, and TSTF-368.

In summary, the sensors, for which the licensee has requested elimination of RTT at SONGS, Units 2 and 3, have all been analyzed in EPRI Report NP-7243, "Investigation of Response Time Testing Requirements." In each case, the response time values have been determined by the sensor manufacturer. The NRC staff has reviewed these systems and the applications in which sensors are used, and finds that these sensors and systems are appropriate for RTT elimination. The specific sensors and systems for which RTT elimination was requested are contained in Table 3.2-4 of CEOG Topical Report NPSD-1167 and Table 1 of this SE.

For these reasons, the NRC staff finds that the proposed TS changes, to be implemented in accordance with the above listed key elements, are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the California State official was notified of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The

Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration and there has been no public comment on such finding (67 FR 18648 dated April 16, 2002). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of these amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: L. Ragavan Date: May 22, 2002

San Onofre Nuclear Generating Station, Units 2 and 3 cc:

Mr. Steve Hsu Mr. R. W. Krieger, Vice President Radiologic Health Branch Southern California Edison Company State Department of Health Services San Onofre Nuclear Generating Station Post Office Box 942732 P. O. Box 128 Sacramento, CA 94327-7320 San Clemente, CA 92674-0128 Mr. Ed Bailey, Radiation Program Director Mr. Douglas K. Porter Radiologic Health Branch Southern California Edison Company State Department of Health Services 2244 Walnut Grove Avenue Post Office Box 942732 (MS 178)

Rosemead, CA 91770 Sacramento, CA 94327-7320 Mr. David Spath, Chief Resident Inspector/San Onofre NPS Division of Drinking Water and c/o U.S. Nuclear Regulatory Commission Environmental Management Post Office Box 4329 P. O. Box 942732 San Clemente, CA 92674 Sacramento, CA 94234-7320 Mayor Chairman, Board of Supervisors City of San Clemente County of San Diego 100 Avenida Presidio 1600 Pacific Highway, Room 335 San Clemente, CA 92672 San Diego, CA 92101 Mr. Dwight E. Nunn, Vice President Eileen M. Teichert, Esq. Southern California Edison Company Supervising Deputy City Attorney San Onofre Nuclear Generating Station City of Riverside P.O. Box 128 3900 Main Street San Clemente, CA 92674-0128 Riverside, CA 92522 Mr. Robert A. Laurie, Commissioner Mr. Gary L. Nolff California Energy Commission Power Projects/Contracts Manager 1516 Ninth Street (MS 31)

Riverside Public Utilities Sacramento, CA 95814 2911 Adams Street Riverside, CA 92504 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Mr. Michael Olson San Onofre Liaison San Diego Gas & Electric Company P.O. Box 1831 San Diego, CA 92112-4150 December 17, 2001