ML051680305

Proposed Change Number NPF-10/15 533 License Amendment Request, Miscellaneous Technical Specification Changes San Onofre Nuclear Generating Station Units 2 and 3

ML051680305
Person / Time
Site:	San Onofre
Issue date:	06/14/2005
From:	Scherer A Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML051680305 (11)

Text

SOUTHERN CALIFORNIA EDISON An EDISON INTERNVATIONAIL" Company A. Edward Scherer Manager of Nuclear Regulatory Affairs June 14, 2004 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Docket Nos. 50-361 and 50-362 Proposed Change Number NPF-10/15 533 License Amendment Request, Miscellaneous Technical Specification Changes San Onofre Nuclear Generating Station Units 2 and 3

Reference:

SCE to NRC letter dated June 29, 2004,

Subject:

Docket Nos. 50-361 and 50-362 Proposed Change Number (NPF-1 0/1 5) 533, License Amendment Request, Miscellaneous Technical Specification Changes, San Onofre Nuclear Generating Station Units 2 and 3

Dear Sir or Madam:

This letter responds to an NRC request for additional information (RAI) concerning Southern California Edison (SCE) request to change the Technical Specifications (TS) for San Onofre Units 2 and 3. The proposed changes revise the Technical Specifications to implement miscellaneous TS changes. provides the SCE response to an NRC question regarding the proposed change to TS 3.4.3.1.2 Pressurizer Heatup / Cooldown Limits Surveillance Requirement. provides the replacement Unit 2 and 3 TS Table of Contents pages 'v" which were not included in the referenced submittal. provides the replacement Unit 2 and 3 TS pages 5.0-26 to reflect the recently issued amendments 195 and 186 deleting section 5.7.1.4 on these pages.

P.O. Box 128 A-c ic San Clemente, CA 92672 949-368-7501 Fax 949-368-7575

Document Control Desk June 14, 2005 If you have any questions or require additional information, please contact Mr.

Jack Rainsberry at (949) 368-7420.

Sincerely,

Enclosures:

1.

SCE response to NRC question regarding the proposed change to TS 3.4.3.1

2.

Replacement Unit 2 and 3 TS Table of Contents pages YV'

3.

Replacement Unit 2 and 3 TS pages 5.0-26 cc:

B. S. Mallett, Regional Administrator, NRC Region IV B. M. Pham, NRC Project Manager, San Onofre Units 2, and 3 C. C. Osterholtz, NRC Senior Resident Inspector, San Onofre Units 2 and 3 S. Y. Hsu, Department of Health Services, Radiologic Health Branch

ENCLOSURE I RESPONSE TO NRC QUESTION ON PROPOSED CHANGE NPF-10115-533 "MISCELLANEOUS TECHNICAL SPECIFICATION CHANGES" SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3

NRC QUESTION REGARDING PCN-533 TS CHANGE SCE's description in PCN-533 for the proposed Technical Specification change to TS 3.4.3.1 Pressurizer Heatup/Cooldown Limits, SR (Surveillance Requirement) 3.4.3.1.2 states:

'This change is proposed to reflect that the pressurizer spray cyclic limits are governed by the temperature differentials between the spray nozzle and the spray line. This is consistent with the Updated Final Safety Analysis Report (UFSAR) Section 3.9.1.1."

Please describe how UFSAR 3.9.1.1 provides a basis for the SR (i.e., when to use the temp differential for the UFSAR, and in particular, where the 500 F temp basis comes from).

RESPONSE

This proposed change replaces the existing requirement frequency, "When less than 4 reactor coolant pumps are operating and for each cycle of auxiliary spray operation,"

with, "For each cycle of auxiliary spray operation and for each cycle of main spray operation when the RCS [reactor coolant system] cold leg temperature is < 500 F." This change would reflect that temperature differentials between the spray nozzle and the spray line govern the pressurizer spray cyclic limits and is consistent with analyses in the Updated Final Safety Analysis Report (UFSAR) Section 3.9.1.1.

The SONGS UFSAR Section 3.9.1.1, Design Transients, identifies transients used in the design and fatigue analysis of American Society of Mechanical Engineers (ASME)

Code Class I components, and provides the basis for SR 3.4.3.1.2. Table 3.9-1 summarizes the transients to be used in stress analysis of Code Class 1 components, where the "Temperature Difference between Pressurizer and Pressurizer Spray During Pressurizer Spray Cycle" requires that, if the maximum temperature difference between the pressurizer and main or auxiliary spray is greater than 200 F, the cumulative usage factor must be calculated to evaluate if the spray system remains acceptable for additional service or if subsequent spray operation shall be restricted.

The current SR only applies when less than 4 reactor coolant pumps (RCPs) are operating. A maximum temperature differential of 200 F is assumed for normal spray operations. Of particular concern is the potential for flow stratification in the pressurizer spray line during operations involving fewer than 4 RCPs. The licensee's updated analysis, however, indicates that the temperature difference between the pressurizer and the spray water could still potentially be greater than 200 F, even with all 4 RCPs operating, if main spray is actuated with RCS cold leg temperature below 500 F. The basis for the 500 F limit follows.

During plant startup, main spray is implemented entering Mode 4 after the second RCP starts, and continues throughout Mode 3. In Mode 3, the pressurizer temperature is normally maintained at 650 F, and the 4th RCP can be started when the RCS cold leg

temperature is greater than 400 F. With all 4 RCPs running, their driving head is enough to provide sufficient bypass flow to keep the spray line warm. However, the temperature difference between the 650 F pressurizer and spray water could still equal or exceed 200 F if main spray is actuated prior to RCS cold leg temperature reaching 500 F, i.e., if a conservative 50 F cushion for heat loss from spray line flow traveling from the RCS cold leg to pressurizer is factored in, the temperature difference between the pressurizer at 650 F and the RCS cold leg at 500 F (650 F - 500 F + 50 F cushion =

200 F) is still 200 F. Only when RCS cold leg temperature is greater than 500 F is there assurance that the temperature difference between the pressurizer and spray water will be less than 200 F and the number of spray cycles are unlimited. Southern Califomia Edison, therefore, concludes that when RCS cold leg temperature is greater than 500 F, there is no longer a need to apply SR 3.4.3.1.2. Additionally, the revised SR 3.4.3.1.2 FREQUENCY requirement is more conservative than the previous one and will result in Surveillances which are focused on the temperature differential requirements.

ENCLOSURE 2 REPLACEMENT UNIT 2 AND UNIT 3 TECHNICAL SPECIFICATION TABLE OF CONTENTS PAGES "v" FOR PROPOSED CHANGE NPF-10115-533 "MISCELLANEOUS TECHNICAL SPECIFICATION CHANGES" SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3

TABLE OF CONTENTS (continued) 3.9 3.9.1 3.9.2 3.9.3 3.9.4 3.9.5 3.9.6 4.0 4.1 4.2 4.3 REFUELING OPERATIONS..........

Boron Concentration.......

Nuclear Instrumentation.....

Containment Penetrations.....

Shutdown Cooling (SDC) and Coolant Circulation-High Water Level Shutdown Cooling (SDC) and Coolant Circulation -Low Water Level...

Refueling Water Level DESIGN FEATURES.............

Site.................

Reactor Core.............

Fuel Storage.............

3.9-1 3.9-1 3.9-2 3.9-4 3.9-6 3.9-8 3.9-10 4.0-1 4.0-1 4.0-1 4.0-4 5.0 5.1 5.2 5.3 5.4 5.5 5.6 5.7 5.8 ADMINISTRATIVE CONTROLS............

Responsibility...............

Organization................

Unit Staff Qualifications.........

Technical Specifications (TS)

Bases Control Procedures, Programs, and Manuals Safety Function Determination Program (SFDP)

Reporting Requirements...........

High Radiation Area............

5.0-1 5.0-1 5.0-2 5.0-5 5.0-6 5.0-7 5.0-21 5.0-23 5.0-30 I

SAN ONOFRE--Unit 2 v

Amendment No.

TABLE OF CONTENTS (continued) 3.9 3.9.1 3.9.2 3.9.3 3.9.4 3.9.5 3.9.6 REFUELING OPERATIONS..................

Boron Concentration................

Nuclear Instrumentation..............

Containment Penetrations..............

Shutdown Cooling (SDC) and Coolant Circulation-High Water Level Shutdown Cooling (SDC) and Coolant Circulation-Low Water Level............

Refueling Water Level 3.9-1 3.9-1 3.9-2 3.9-4 3.9-6 3.9-8 3.9-10 4.0 4.1 4.2 4.3 DESIGN FEATURES Site.................

Reactor Core.............

Fuel Storage.............

4.0-1 4.0-1 4.0-1 4.0-4 5.0 5.1 5.2 5.3 5.4 5.5 5.6 5.7 5.8 ADMINISTRATIVE CONTROLS............

Responsibility...............

Organization.....

Unit Staff Qualifications Technical Specifications (TS) Bases Control Procedures, Programs, and Manuals.....

Safety Function Determination Program (SFDP)

Reporting Requirements...........

High Radiation Area............

5.0-1 5.0-1 5.0-2 5.0-5 5.0-6 5.0-7 5.0-21 5.0-23 5.0-30 SAN ONOFRE--Unit 3 v

Amendment No.

ENCLOSURE 3 REPLACEMENT UNIT 2 AND UNIT 3 TECHNICAL SPECIFICATION PAGES 5.0-26 REFLECTING RECENTLY ISSUED AMENDMENTS 195 AND 186 DELETING SECTION 5.7.1.4 ON THESE PAGES, FOR PROPOSED CHANGE NPF-10115-533 "MISCELLANEOUS TECHNICAL SPECIFICATION CHANGES" SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3

Reporting Requirements 5.7 5.7 Reporting Requirements (continued) 5.7.1.4 5.7.1.5 (Del eted)

CORE OPERATING LIMITS REPORT (COLR)

a.

Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

1.

Specification 3.1.4, "Moderator Temperature Coefficient;"

2.

Specification 3.1.5, "Control Element Assembly (CEA)

Alignment;"1 I

3.

Specification 3.1.7, "Regulating CEA Insertion Limits;"

4.

Specification 3.1.8, "Part Length Control Element Assembly Insertion Limits;"

5.

Specification 3.2.1, "Linear Heat Rate;"

6.

Specification 3.2.4, "Departure From Nucleate Boiling Ratio;"

7.

Specification 3.2.5, "Axial Shape Index;"

8.

Specification 3.9.1, "Boron Concentration."

b.

The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

I I

(continued)

SAN ONOFRE--UNIT 2 5.0-26 Amendment No.

Reporting Requirements 5.7 5.7 Reporting Requirements (continued) 5.7.1.4 (Deleted) 5.7.1.5 CORE OPERATING LIMITS REPORT (COLR)

a.

Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

1.

Specification 3.1.4, "Moderator Temperature Coefficient;"

2.

Specification 3.1.5, "Control Element Assembly (CEA)

Alignment;"

3.

Specification 3.1.7, "Regulating CEA Insertion Limits;"

4.

Specification 3.1.8, "Part Length Control Element Assembly Insertion Limits;"

5.

Specification 3.2.1, "Linear Heat Rate;"

6.

Specification 3.2.4, "Departure From Nucleate Boiling Ratio;"

7.

Specification 3.2.5, "Axial Shape Index;"

8.

Specification 3.9.1, "Boron Concentration."

b.

The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

(continued)

SAN ONOFRE--UNIT 3 5.0-26 Amendment No.