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MONTHYEARML0329503052003-10-22022 October 2003 SONGS 2&3 Rai Letter - Steam Generator Pressure-Low Allowable Value (Tacs. MC0200, MC0201) Project stage: RAI ML0421002442004-07-23023 July 2004 Proposed Change Number (PCN) 545 Request to Revise Technical Specifications 3.3.1 and 3.3.5 Project stage: Request 2003-10-22
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Category:Letter
MONTHYEARML24022A1492024-01-17017 January 2024 Independent Spent Fuel Storage Installation, Revision 4 to the Physical Security Plan IR 05000361/20230062023-11-29029 November 2023 NRC Inspection Report 05000361/2023-006 and 05000362/2023-006 ML23333A0682023-11-22022 November 2023 (SONGS) Units 1, 2, 3 and Independent Spent Fuel Storage Installation - Notification of Change in Nuclear Officer IR 05000361/20230052023-10-11011 October 2023 NRC Inspection Report 05000361/2023005 and 05000362/2023005 ML23276A5942023-09-28028 September 2023 and Independent Spent Fuel Storage Installation - Supplement to Decommissioning Funding Status Reports ML23268A0922023-09-20020 September 2023 Generation Station, Units 1, 2 and 3, and the Independent Spent Fuel Storage Facility (ISFSI) - Re-Registration of Dry Fuel Storage Casks for Amended Certificate of Compliance No. 1040 IR 05000361/20230012023-09-13013 September 2023 NRC Inspection Report 05000361 2023-001 and 05000362 2023-004 ML23240A5372023-08-18018 August 2023 Confirmatory Survey Activities Summary and Results for the Unit 2 and 3 Intake Structures at the San Onofre Nuclear Generating Station San Clemente CA ML23129A1802023-06-14014 June 2023 Cover Letter to State of CA on Draft EA Regarding San Onofre ISFSI Updated DFPs IR 05000361/20230032023-05-31031 May 2023 NRC Inspection Report 05000361/2023003 and 05000362/2023003 IR 05000361/20230022023-05-23023 May 2023 NRC Inspection Report 05000361/2023-002 and 05000362/2023-002 ML23137A1032023-05-11011 May 2023 (Songs), Units 1, 2 and 3, and Independent Spent Fuel Storage Installation - 2022 Annual Radiological Environmental Operating Report ML23123A0932023-04-28028 April 2023 (Songs), Units 1, 2 and 3, Submittal of Annual Radioactive Effluent Release Report - 2022 ML23230A0882023-04-10010 April 2023 Independent Spent Fuel Storage Installation - Decommissioning Quality Assurance Plan ML23094A1272023-03-29029 March 2023 Independent Spent Fuel Storage Installation - 10 CFR 50.82(a)(8)(v and VII) and 10 CFR 72.30(c) Decommissioning Funding Status Report 2021 ML23094A1332023-03-29029 March 2023 Nuclear Property Insurance ML23062A1172023-02-28028 February 2023 Generation Station Units 1, 2 and 3, Annual Radioactive Effluent Release Report for Independent Spent Fuel Storage Installation - 2022 ML22361A1022023-02-24024 February 2023 Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities ML23059A2812023-02-22022 February 2023 (Songs), Units 1, 2 and 3, 2022 Annual Turtle Incidental Take Report ML23046A3792023-02-22022 February 2023 NRC Inspection Report 050-00361/2023-001 and 050-00362/2023-001 ML23045A2022023-02-0909 February 2023 Submittal of Annual Corporate Financial Reports for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 for Fy Ending June 30, 2022 ML22287A1352023-01-0505 January 2023 Issuance of Exemption from Title 10 of the Code of Federal Regulations Part 72.106(B), Independent Spent Fuel Storage Installation Controlled Area Boundary (L-2021-LLE-0056) ML22348A0622023-01-0404 January 2023 NRC to SCE, Transmittal of the National Marine Fisheries Service'S December 12, 2022, Letter of Concurrence for Decommissioning of San Onofre Nuclear Generating Statiion, Units 2 and 3 IR 05000206/20220062022-12-15015 December 2022 NRC Inspection Report 05000206/2022006, 05000361/2022-006, and 05000362/2022-006 ML22347A2122022-12-12012 December 2022 NMFS to NRC, Endangered Species Act Section 7(a)(2) Concurrence Letter for Decommissioning of the San Onofre Nuclear Generating Station ML22340A6652022-12-0505 December 2022 Letter from John Fassell, Chief; Re., State of California Department of Public Health Review and Comments on SONGS Draft Environmental Assessment ML22333A8192022-11-21021 November 2022 Submittal of San Onofre Nuclear Generating Station, Units 2 and 3, Defueled Safety Analysis Report, Revised November 2022 IR 05000361/20220052022-11-17017 November 2022 NRC Inspection Report 05000361/2022-005 and 05000362/2022-005 ML22301A1462022-10-20020 October 2022 Report of Violations of the National Pollutant Discharge Elimination System Permit San Onofre Nuclear Generating Station (Songs), Units 2 and 3 ML22277A0162022-09-29029 September 2022 Independent Spent Fuel Storage Installation Response to Request for Additional Information Regarding Request for Exemption from 10 CFR 72.106(b) IR 05000361/20220042022-09-26026 September 2022 NRC Inspection Report 05000361/2022-004 and 05000362/2022-004 ML22238A0552022-08-29029 August 2022 U.S. Nuclear Regulatory Commission'S Analysis of Southern California Edison'S Decommissioning Funding Status Report for San Onofre Nuclear Generating Station, Units 1, 2, and 3 ML22234A1602022-07-31031 July 2022 Final Report Per 10 CFR Part 21, Degraded Snubber SF1154 Hydraulic Fluid Batch No. 18CLVS431 ML22207B8612022-07-26026 July 2022 NRC (Public) Inspection Report 05000361/2022003; 05000362/2022003 IR 05000361/20220032022-07-26026 July 2022 NRC Inspection Report (Public) 05000361-2022003 and 05000362-2022003 (002) IR 05000361/20220022022-05-12012 May 2022 NRC Inspection Report 05000361/2022-002 and 05000362/2022-002 ML22136A0842022-05-12012 May 2022 Independent Spent Fuel Storage Installation, 2021 Annual Radiological Environmental Operating Report ML22122A0402022-04-28028 April 2022 (Songs), Units 1, 2 and 3 - Annual Radioactive Effluent Release Report - 2021 ML22105A5662022-04-0505 April 2022 20053 Letter - OI Closure to Licensee - Wrongdoing Signed ML22081A1692022-03-31031 March 2022 SONGS Application Acceptance Proposed Exemption from Title 10 of the CFR, Part 72.106(b), ISFSI Controlled Boundary IR 05000206/20214022022-03-24024 March 2022 Notice of Violation, NRC Inspection Report 05000206/2021402, 05000361/2021402, 05000362/2021402, and 07200041/2021401; and Investigation Report 4-2021-004- Public- Cover Letter ML22084A0552022-03-23023 March 2022 10 CFR 50.82(a)(8Xv and VII) and 10 CFR 72.30(c) Decommissioning Funding Status Report 2021 San Onofre Nuclear Generating Station Units 1, 2, and 3 and Independent Spent Fuel Storage Installation IR 05000361/20220012022-03-14014 March 2022 NRC Inspection Report 05000361/2022-001; 05000362/2022-001 ML22066B0242022-03-0303 March 2022 (Songs), Units 1, 2, and 3, and the Independent Spent Fuel Storage Installation - Revision 2 to the ISFSI-Only Emergency Plan and Associated Changes to Emergency Plan Implementing Procedures ML22062B0282022-02-28028 February 2022 and Independent Spent Fuel Storage Installation (Isfsi), Response to Request for Supplemental Information Regarding Request for Exemption from 10 CFR 72.106(b) ML22059B0392022-02-25025 February 2022 International, Proprietary Information to Support SCE Exemption ML22060A1132022-02-24024 February 2022 Nuclear Property Insurance ML22060A1152022-02-24024 February 2022 Generation Station Units 1, 2 and 3, Annual Radioactive Effluent Release Report for Independent Spent Fuel Storage Installation - 2021 ML22048B4972022-02-15015 February 2022 (Songs), Units 1, 2 and 3 - 2021 Annual Turtle Incidental Take Report ML22031A1112022-01-26026 January 2022 (Songs), Units 2 and 3 - Annual Corporate Financial Reports 2024-01-17
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML21117A3492021-03-30030 March 2021 March 30, 2021, Email from Public Watchdogs on Providing New Information to Its October 13, 2020, 2.206 Petition ML21068A2722021-03-0909 March 2021 SONGS Endangered Species Act Additional Information Request ML20343A1292020-12-0808 December 2020 NRR E-mail Capture - Request for Additional Information ML18193A2002018-07-19019 July 2018 SONGS ISFSI Only Dqap RAI ML15083A4552015-03-27027 March 2015 and Independent Spent Fuel Storage Installation - Request for Additional Information Decommissioning Quality Assurance Program Review ML15071A1842015-03-19019 March 2015 Independent Spent Fuel Storage Installation - Request for Additional Information Regarding the 10 CFR 50.54(p) Changes to the Security Plans ML15042A3942015-01-23023 January 2015 NRR E-mail Capture - SONGS - Draft RAI Permanently Defueled Technical Specifications License Amendment Request ML15033A0522014-12-11011 December 2014 NRR E-mail Capture - SONGS - Draft RAI Permanently Defueled Technical Specifications License Amendment Request ML14248A5902014-09-18018 September 2014 Independent Spent Fuel Storage Installation - Request for Additional Information, Amendment Request to Revise Emergency Plan to Support Permanently Defueled Condition ML14248A5602014-09-18018 September 2014 Independent Spent Fuel Storage Installation - Request for Additional Information, Amendment Request to Revise Emergency Action Level Scheme to Support Permanently Defueled Condition ML14258A0172014-09-11011 September 2014 NRR E-mail Capture - SONGS - Revised Draft RAI Concerning TS Section 5 Administrative Controls License Amendment Request (TACs MF2954 and MF2955) ML14209A0052014-08-27027 August 2014 Request for Additional Information, Exemption Request from 10 CFR 50.47 and 10 CFR Part 50 Appendix E, Discontinue Offsite Emergency Planning Activities and Reduce Scope of Onsite Emergency Planning (TAC MF3835-MF3837) ML14139A4782014-06-0505 June 2014 Request for Additional Information, License Amendment Request to Revise Technical Specifications 5.1, 5.2, and 5.3 to Reflect Reduced Staffing/Training in Permanently Shutdown and Defueled Condition ML14093A6772014-05-0101 May 2014 SONGS - Request for Additional Information Concerning Pre-Emption Authority ML13352A0912013-12-30030 December 2013 Decommissioning Funding Status Report - Request for Additional Information ML13191A8372013-09-12012 September 2013 Request for Additional Information, Review of Decommissioning Funding Status Report ML13154A4312013-06-0404 June 2013 Rai'S Following Ifib Analysis of Edison'S 2013 Decommissioning Funding Status Report for San Onofre Units 2 and 3 ML13113A2562013-05-10010 May 2013 Request for Additional Information No. 73 Regarding Response to Confirmatory Action Letter ML13072A0542013-03-18018 March 2013 Redacted, Request for Additional Information, Nos. 33-67, Southern California Edison'S Response to Nrc'S Confirmatory Action Letter ML13074A6872013-03-15015 March 2013 Email, Draft Request for Additional Information, Nos. 68-72, Southern California Edison'S Response to Nrc'S Confirmatory Action Letter ML13053A1842013-02-21021 February 2013 Draft Request for Additional Information, Nos. 53-67, Southern California Edison'S Response to Nrc'S Confirmatory Action Letter ML13056A0922013-02-20020 February 2013 Email, Draft Request for Additional Information Nos. 38-52, Southern California Edison'S Response to Nrc'S Confirmatory Action Letter ML13053A3672013-02-0101 February 2013 E-mail, Draft Request for Additional Information Southern California Edison'S Response to Nrc'S Confirmatory Action Letter ML12356A1982012-12-20020 December 2012 Email, Request for Additional Information, Round 3, Review of Southern California Edison'S Response to Nrc'S 3/27/2012 Confirmatory Action Letter (CAL) 4-12-001 and Return to Service Report ML12345A4272012-12-10010 December 2012 Revised Email, Request for Additional Information Review of Southern California Edison'S Response to Nrc'S 3/27/2012 Confirmatory Action Letter (CAL) 4-12-001 and Return to Service Report ML12338A1102012-11-30030 November 2012 Email, Request for Additional Information Southern California Edison'S Response to Nrc'S Confirmatory Action Letter (CAL) 4-12-001 Dated March 27, 2012 ML12313A4752012-11-0808 November 2012 Request for Additional Information Email, Relief Request IST-4-P-2, ASME OM Code Requirements for Testing CSS and LPSI Pumps, Fourth 10-Year Inservice Inspection Interval ML12297A3972012-10-23023 October 2012 Request for Additional Information Email, Relief Request ISI-3-36, Reactor Coolant Pressure Boundary Testing, Third 10-Year Inservice Inspection Interval ML12283A2302012-10-0909 October 2012 Request for Additional Information Email, Round 3 W/Corrected Due Date, Request to Revise Technical Specification (TS) 2.1.1.2, TS 4.2.1, and TS 5.7.1.5, to Support Unrestricted Use of Areva Fuel ML12283A2252012-10-0909 October 2012 Request for Additional Information Email, Round 3, Request to Revise Technical Specification (TS) 2.1.1.2, TS 4.2.1, and TS 5.7.1.5, to Support Unrestricted Use of Areva Fuel ML12220A0492012-08-0707 August 2012 Request for Additional Information Email, Round 2, License Amendment Request to Revise Technical Specification (TS) 2.1.1.2, TS 4.2.1, and TS 5.7.1.5, to Support Unrestricted Use of Areva Fuel ML12207A2612012-08-0101 August 2012 Redacted, Request for Additional Information, License Amendment Request to Revise Technical Specification (TS) 2.1.1.2, TS 4.2.1, and TS 5.7.1.5, to Support Unrestricted Use of Areva Fuel ML12201A1552012-07-19019 July 2012 R. Onge Ltr Request for Additional Information Decommissioning Funding ML12056A0502012-03-12012 March 2012 Enclosure 4 - Recommendation 2.3: Flooding ML12056A0512012-03-12012 March 2012 Enclosure 5 - Recommendation 9.3: Emergency Preparedness ML12056A0482012-03-12012 March 2012 Enclosure 2 - Recommendation 2.1: Flooding ML12056A0472012-03-12012 March 2012 Enclosure 1 - Recommendation 2.1: Seismic ML12056A0492012-03-12012 March 2012 Enclosure 3 - Recommendation 2.3: Seismic ML1200603242012-01-19019 January 2012 Fleet, RAI, Proposed Alternative to Use American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Case N-789 (N-789) ML1126604602011-10-14014 October 2011 Request for Additional Information Regarding Use of American Concrete Institute Reports for Restoration of Unit 3 Containment ML11182C0322011-06-30030 June 2011 Notification of Inspection (Inspection Report 05000361; 05000362/2011004) and Request for Information ML1113003952011-05-10010 May 2011 Email, Draft Request for Additional Information, Review of Biennial Decommissioning Funding Status Report ML1113004002011-05-10010 May 2011 Draft Request for Additional Information, Review of Biennial Decommissioning Funding Status Report ML1112307842011-05-0303 May 2011 Draft Request for Additional Information, Relief Requests ISI-3-32 Through ISI-3-34, Alternative to Requirements for Examinations of Welds and Core Support Structure Surfaces, Third 10-Year Inservice Inspection ML1106006612011-03-0101 March 2011 Draft Generic Request for Additional Information, License Amendment Request to Revise License Condition and Approve Cyber Security Plan ML1024301262010-08-31031 August 2010 Request for Additional Information Relief Request ISI-3-31 ML1022404532010-08-11011 August 2010 Draft Request for Additional Information LAR on Fuel Assembly Movement ML0933601212009-12-0202 December 2009 Request for Additional Information Relief Request ISI-3-30 ML0831705532008-12-0808 December 2008 Request for Additional Information, License Amendment Request to Support Replacement Steam Generators ML0831901202008-11-26026 November 2008 Request for Additional Information Test Protocol Used in the Testing at Vuez 2021-03-09
[Table view] |
Text
October 22, 2003 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 -
REQUEST FOR ADDITIONAL INFORMATION REGARDING STEAM GENERATOR PRESSURE-LOW ALLOWABLE VALUE (TAC NOS. MC0200 AND MC0201)
Dear Mr. Ray:
By letter dated July 28, 2003, Southern California Edison Company submitted for NRC staff review proposed change number 545, Request to Revise Technical Specifications 3.3.1 and 3.3.5. In this amendment proposal, you requested to revise Technical Specification 3.3.1, RPS Instrumentation - Operating, and 3.3.5, ESFAS Instrumentation. Specifically, the changes would replace the requirement for the Steam Generator Pressure - Low allowable value from its current value of 729 psia to a revised value of 717 psia.
The staff has completed its preliminary review of your submittal, and has identified a number of items for which additional information is needed to continue its review. The enclosed request for additional information contains questions that need your response. We request that the additional information be provided within 60 days of receipt of this letter. This 60-day response time frame was discussed with Mr. Jack Rainsberry of your staff on October 14, 2003. If circumstances result in the need to revise your response date, or if you have any questions, please contact me at 301-415-8450.
Sincerely,
/RA/
Bo M. Pham, 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:
Request for Additional Information cc w/encls: See next page
October 22, 2003 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 -
REQUEST FOR ADDITIONAL INFORMATION REGARDING STEAM GENERATOR PRESSURE-LOW ALLOWABLE VALUE (TAC NOS. MC0200 AND MC0201)
Dear Mr. Ray:
By letter dated July 28, 2003, Southern California Edison Company submitted for NRC staff review proposed change number 545, Request to Revise Technical Specifications 3.3.1 and 3.3.5. In this amendment proposal, you requested to revise Technical Specification 3.3.1, RPS Instrumentation - Operating, and 3.3.5, ESFAS Instrumentation. Specifically, the changes would replace the requirement for the Steam Generator Pressure - Low allowable value from its current value of 729 psia to a revised value of 717 psia.
The staff has completed its preliminary review of your submittal, and has identified a number of items for which additional information is needed to continue its review. The enclosed request for additional information contains questions that need your response. We request that the additional information be provided within 60 days of receipt of this letter. This 60-day response time frame was discussed with Mr. Jack Rainsberry of your staff on October 14, 2003. If circumstances result in the need to revise your response date, or if you have any questions, please contact me at 301-415-8450.
Sincerely,
/RA/
Bo M. Pham, 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:
Request for Additional Information cc w/encls: See next page DISTRIBUTION PUBLIC RidsNrrDlpmLpdiv (H. Berkow) RidsRgn4MailCenter (K. Kennedy)
PDIV-2 r/f RidsAcrsAcnwMailCenter RidsNrrPMBPham RidsNrrLAMMcAllister EMarinos RidsOgcRp PRebstock ACCESSION NO: ML032950305 NRR-088
- Concurred via email input OFFICE PDIV-2/PM PDIV-1/LA *EEIB/SC PDIV-2/SC NAME BPham MMcAllister EMarinos SDembek DATE 10/20/03 10/22/03 9/30/03 10/22/03 OFFICIAL RECORD COPY DOCUMENT NAME: C:\ADAMS\Cache\ML0329503050.wpd
San Onofre Nuclear Generating Station, Units 2 and 3 cc:
Mr. Raymond Waldo, Plant Manager Mr. Ed Bailey, Radiation Program Director Nuclear Generation Radiologic Health Branch Southern California Edison Company State Department of Health Services San Onofre Nuclear Generating Station Post Office Box 942732 (MS 178)
P. O. Box 128 Sacramento, CA 94327-7320 San Clemente, CA 92674-0128 Resident Inspector/San Onofre NPS Mr. Douglas K. Porter c/o U.S. Nuclear Regulatory Commission Southern California Edison Company Post Office Box 4329 2244 Walnut Grove Avenue San Clemente, CA 92674 Rosemead, CA 91770 Mayor Mr. David Spath, Chief City of San Clemente Division of Drinking Water and 100 Avenida Presidio Environmental Management San Clemente, CA 92672 P. O. Box 942732 Sacramento, CA 94234-7320 Mr. Dwight E. Nunn, Vice President Southern California Edison Company Chairman, Board of Supervisors San Onofre Nuclear Generating Station County of San Diego P.O. Box 128 1600 Pacific Highway, Room 335 San Clemente, CA 92674-0128 San Diego, CA 92101 Mr. James D. Boyd, Commissioner Eileen M. Teichert, Esq. California Energy Commission Supervising Deputy City Attorney 1516 Ninth Street (MS 31)
City of Riverside Sacramento, CA 95814 3900 Main Street Riverside, CA 92522 Mr. Joseph J. Wambold, Vice President Southern California Edison Company Mr. Gary L. Nolff San Onofre Nuclear Generating Station Power Projects/Contracts Manager P.O. Box 128 Riverside Public Utilities San Clemente, CA 92764-0128 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
REQUEST FOR ADDITIONAL INFORMATION SOUTHERN CALIFORNIA EDISON COMPANY SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 STEAM GENERATOR LOW PRESSURE ALLOWABLE VALUE DOCKET NOS. 50-361 AND 50-362 The following questions are provided after a preliminary review of Southern California Edisons (SCEs) submittal dated July 28, 2003, proposed change number 545, Request to Revise Technical Specifications 3.3.1 and 3.3.5.
- 1. Please show that the margin between the proposed Allowable Value and the Analytical Limit (AV/AL) is sufficient to accommodate all applicable uncertainties, including uncertainties not addressed in channel testing. For example: the calibration of the steam generator (SG) Pressure transmitters is not adjusted or confirmed in the channel check, but it has an obvious influence over the value of SG pressure at which channel trip actually occurs. Another example: testing is performed under whatever environmental conditions happen to be in effect at the time of the test, but a change in environment to the design basis limit could introduce additional uncertainty in channel calibration. Note that the setpoint calculation (Attachment G to the SCE letter) does not appear to take either of the effects in the foregoing examples into account.
- 2. Please indicate what potential influences are not addressed in channel testing, and explain how they are accommodated in the AV/AL margin.
- 3. The setpoint calculation identifies numerous assumptions, many of which assert specific quantitative data, for which no substantiation or justification is provided (Section 3). The calculation also relies extensively upon memoranda and other documentation that do not appear to be subject to formal verification and quality control (Section 5). Please explain how the adequacy of the calculations is ensured despite these apparent deficiencies.
- 4. Please provide a copy of SCE Engineering Design Standard JS-123-103C, Revision 1, and show that the setpoint calculation is in accordance with that standard and that any deviation from the standard is documented and justified. Please note the following concerns:
- a. Enclosure 2 to the referenced letter indicates that the proposed Allowable Value is based, in part, upon a reduced uncertainty estimate which is itself based upon a setpoint methodology derived from Revision 1 of SCE Engineering Design Standard JS-123-103C. It does not directly state that the Allowable Value was derived in accordance with the design standard. (See the second paragraph of Section 4.0, on page 3 of the licensees Enclosure 2.) The footnote associated with the referenced paragraph indicates that Revision 0 of the design standard was reviewed by an NRC inspection team in 1991, and cites an NRC inspection
report transmitted via letter dated April 12, 1991 as documentation. The footnote identifies some of the changes from Revision 0 to Revision 1, but does not provide any detail.
- b. The setpoint calculation, Attachment G to the SCE letter, lists the SCE Engineering Design Standard as reference #64. It does not indicate that the calculation is based upon this design standard. It cites the design standard only as a source of general information (Sections 1.2 and 2.0), and as a reference for a reduction of the channel uncertainty value (Section 4.5-VI).
- c. The NRC letter of April 12, 1991, and the Notice of Violation and the Inspection Report attached to it indicate that the methodology used in the computation of certain specific values is acceptable. They do not identify any particular methodology specification, and they do not address the acceptability of the methodology for other applications. The report does mention JS-123-103C Revision 0 (page 20, formal citation on page 25), but indicates that it has been used only as a non-mandatory guidance document. The report does not indicate that this document was itself reviewed for acceptability as a basis for setpoint and Allowable Value calculations in general.
- d. The staff therefore does not find from the information provided to date that the methodology employed in the derivation of the proposed Allowable Value has been previously reviewed or accepted by the NRC. The staff does not find a firm connection between the submitted calculation and the design standard addressed in the licensees Enclosure 2. The staff does not find that the design standard has ever been reviewed by the NRC for general use, and does find that the current revision has never been submitted to the NRC for review. The staff does not find that the brief description of the changes in the design standard from Revision 0 to Revision 1 provides sufficient information to permit evaluation of the changes.