ML062960355
| ML062960355 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/20/2006 |
| From: | Kalyanam N NRC/NRR/ADRO/DORL/LPLIV |
| To: | Rosenblum R Southern California Edison Co |
| Kalynanam N, NRR/DORL/LP4, 415-1480 | |
| References | |
| TAC MB9853, TAC MB9854 | |
| Download: ML062960355 (5) | |
Text
October 20, 2006 Mr. Richard M. Rosenblum Senior Vice President and Chief Nuclear Officer 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 -
RECEIPT OF RESPONSE TO GENERIC LETTER 2003-01, CONTROL ROOM HABITABILITY (TAC NOS. MB9853 AND MB9854)
Dear Mr. Rosenblum:
The Nuclear Regulatory Commission acknowledges the receipt of your responses to Generic Letter (GL) 2003-01, Control Room Habitability, dated August 5, 2003 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML032230360, Reference 1), November 26, 2003 (ADAMS Accession Number ML033370814, Reference 2),
December 9, 2003 (ADAMS Accession Number ML033450328), and September 17, 2004 (ADAMS Accession Number ML042650353, Reference 3). This letter provides a status of your response and describes any additional information that may be necessary to consider your response to GL 2003-01 complete.
The GL requested that you confirm that your control rooms meet their design bases (e.g.,
General Design Criteria (GDC) 1, 3, 4, 5, and 19, draft GDC, or principal design criteria), with special attention to the determination: (1) of the most limiting unfiltered and/or filtered inleakage into the control room and comparison to values used in your design bases for meeting control room operator dose limits from accidents (GL 2003-01, Item 1a), (2) that the most limiting unfiltered inleakage is incorporated into your hazardous chemical assessments (GL 2003-01, Item 1b), and (3) that reactor control capability is maintained in the control room or at the alternate shutdown location in the event of smoke (GL 2003-01, Item 1b).
Reference 3 contained the results of American Society for Testing Materials (ASTM)- E741, Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution, tracer gas tests for the San Onofre Nuclear Generating Station, Units 2 and 3, control room which is common to both units and pressurized for accident mitigation. The maximum tested value for inleakage into the Control Room Envelope (CRE) was 67 standard cubic feet per minute (scfm), which is more than the value of 10 cfm assumed in your current design-basis radiological dose analyses for Control Room Habitability (CRH), and using Alternative Source Term (AST) methodology, the CRE was determined to be non-conforming but operable. In Reference 3, you stated you would submit a license amendment request (LAR) to change the accident source term to an AST and on December 27, 2004, you submitted the LAR (ADAMS Accession Number ML043650403). Additionally, it was determined that the maximum tested value for inleakage into the CRE was 645 (+/- 17) scfm for hazardous chemical events which is
R. Rosenblum less than the value of 2,201.3 scfm assumed in your current design-basis hazardous chemical analysis. You also indicated, in Reference 1, that reactor control capability is maintained from either the control room or the evacuation shutdown panel in the event of smoke.
The GL further requested that you assess your Technical Specifications (TSs) to determine if they verify the integrity of the CRE, including ongoing verification of the inleakage assumed in the design-basis analysis for control room habitability in light of the demonstrated inadequacy of a delta () P measurement to alone provide such verification (GL 2003-01, Item 1c). As permitted by the GL, you provided a schedule for revising the surveillance requirement (SR) in the TSs to reference an acceptable surveillance methodology. In Reference 2, you committed to submit a proposed TS change to adopt TS SRs that verify CRH per Technical Specification Task Force Traveler (TSTF)-448 within 90 days following NRC approval of TSTF-448.
The GL also requested information on any compensatory measures in use to demonstrate control room habitability, and plans to retire them (GL 2003-01, Item 2). In response, you stated that there are no compensatory measures needed to be in place to demonstrate control room habitability, however, your reliance on AST methodology to demonstrate control room operabilty is considered a compensatory measure. As noted above, you have submitted an LAR to revise your design-basis radiological dose analysis using the AST methodology and when the license amendment is issued, reliance on AST methodology will no longer be considered a compensatory measure.
The information you provided also supported the conclusion that you are committed toward meeting the GDC regarding control room habitability.
Your commitment to submit an LAR based on TSTF-448, following our formal review and approval, is acceptable for purposes of closing out your response to GL 2003-01. The staff will monitor submission of the LAR and interact with you as necessary during the amendment process.
If you have any questions, please contact me at (301) 415-1480.
Sincerely,
/RA/
N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362 cc: See next page
R. Rosenblum less than the value of 2,201.3 scfm assumed in your current design-basis hazardous chemical analysis. You also indicated, in Reference 1, that reactor control capability is maintained from either the control room or the evacuation shutdown panel in the event of smoke.
The GL further requested that you assess your Technical Specifications (TSs) to determine if they verify the integrity of the CRE, including ongoing verification of the inleakage assumed in the design-basis analysis for control room habitability in light of the demonstrated inadequacy of a delta () P measurement to alone provide such verification (GL 2003-01, Item 1c). As permitted by the GL, you provided a schedule for revising the surveillance requirement (SR) in the TSs to reference an acceptable surveillance methodology. In Reference 2, you committed to submit a proposed TS change to adopt TS SRs that verify CRH per Technical Specification Task Force Traveler (TSTF)-448 within 90 days following NRC approval of TSTF-448.
The GL also requested information on any compensatory measures in use to demonstrate control room habitability, and plans to retire them (GL 2003-01, Item 2). In response, you stated that there are no compensatory measures needed to be in place to demonstrate control room habitability, however, your reliance on AST methodology to demonstrate control room operabilty is considered a compensatory measure. As noted above, you have submitted an LAR to revise your design-basis radiological dose analysis using the AST methodology and when the license amendment is issued, reliance on AST methodology will no longer be considered a compensatory measure.
The information you provided also supported the conclusion that you are committed toward meeting the GDC regarding control room habitability.
Your commitment to submit an LAR based on TSTF-448, following our formal review and approval, is acceptable for purposes of closing out your response to GL 2003-01. The staff will monitor submission of the LAR and interact with you as necessary during the amendment process.
If you have any questions, please contact me at (301) 415-1480.
Sincerely,
/RA/
N. Kalyanam, Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362 cc: See next page DISTRIBUTION:
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RidsNrrDorlDpr ACCESSION NO: ML062960355
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March 2006 San Onofre Nuclear Generating Station Units 2 and 3 cc:
Mr. Daniel P. Breig Southern California Edison Company San Onofre Nuclear Generating Station P. O. Box 128 San Clemente, CA 92674-0128 Mr. Douglas K. Porter, Esquire Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, CA 91770 Mr. David Spath, Chief Division of Drinking Water and Environmental Management P. O. Box 942732 Sacramento, CA 94234-7320 Chairman, Board of Supervisors County of San Diego 1600 Pacific Highway, Room 335 San Diego, CA 92101 Mark L. Parsons Deputy City Attorney City of Riverside 3900 Main Street Riverside, CA 92522 Mr. Gary L. Nolff Assistant Director - Resources City of Riverside 3900 Main Street Riverside, CA 92522 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Mr. Michael R. Olson San Diego Gas & Electric Company 8315 Century Park Ct. CP21G San Diego, CA 92123-1548 Director, Radiologic Health Branch State Department of Health Services P.O. Box 997414, MS 7610 Sacramento, CA 95899-7414 Resident Inspector/San Onofre NPS c/o U.S. Nuclear Regulatory Commission Post Office Box 4329 San Clemente, CA 92674 Mayor City of San Clemente 100 Avenida Presidio San Clemente, CA 92672 Mr. James T. Reilly Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Mr. James D. Boyd, Commissioner California Energy Commission 1516 Ninth Street (MS 31)
Sacramento, CA 95814 Mr. Ray Waldo, Vice President Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92764-0128 Mr. Brian Katz Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92764-0128
March 2006 San Onofre Nuclear Generating Station Units 2 and 3 cc:
Mr. Steve Hsu Department of Health Services Radiologic Health Branch MS 7610, P.O. Box 997414 Sacramento, CA 95899 Mr. A. Edward Scherer Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128