ML072550211

Request for Additional Information on the Proposed Amendment to Revise Degraded Voltage Instrumentation (Tac Nos. MD4419 and MD4420)

ML072550211
Person / Time
Site:	San Onofre
Issue date:	09/24/2007
From:	Kalyanam N NRC/NRR/ADRO/DORL/LPLIV
To:	Rosenblum R Southern California Edison Co
Kalyanam N, NRR/DORL/LP4, 415-1480
References
TAC MD4419, TAC MD4420
Download: ML072550211 (7)

Text

September 24, 2007 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 -

REQUEST FOR ADDITIONAL INFORMATION ON THE PROPOSED AMENDMENT TO REVISE DEGRADED VOLTAGE INSTRUMENTATION (TAC NOS. MD4419 AND MD4420)

Dear Mr. Rosenblum:

By letter dated February 8, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML070440046), Southern California Edison (the licensee) submitted an application to revise the San Onofre Nuclear Generating Station, Units 2 and 3 (SONGS 2 and 3), Technical Specifications (TS) Surveillance Requirement (SR) 3.3.7.3.a to lower the allowable value for dropout and raise the allowable value for pickup of the degraded voltage function, and revise TS SR 3.8.1 to lower the Diesel Generator minimum output voltage due to lower settings for the degraded voltage function.

After reviewing your request, the Nuclear Regulatory Commission staff has determined that additional information outlined in the enclosure is needed to complete the review. We discussed this information with your staff by telephone and they agreed to provide the additional information requested within 45 days of the receipt of this letter.

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

Enclosure:

Request for Additional Information cc w/encl: See next page

ML072550211 *No major change from Staff provided RAI.

OFFICE NRR/LPL4/PM NRR/LPL4/LA NRR/DE/EICB* NRR/LPL4/BC NAME NKalyanam JBurkhardt WKemper THiltz DATE 9/24/07 9/21/07 9/6/07 9/24/07 San Onofre Nuclear Generating Station Units 2 and 3 cc:

Mr. Raymond W. Waldo, Vice President, Director, Radiologic Health Branch Nuclear Generation State Department of Health Services Southern California Edison Company P.O. Box 997414, MS 7610 San Onofre Nuclear Generating Station Sacramento, CA 95899-7414 P.O. Box 128 San Clemente, CA 92674-0128 Resident Inspector San Onofre Nuclear Generating Station Mr. Douglas K. Porter, Esquire 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 Dr. David Spath, Chief City of San Clemente Division of Drinking Water and 100 Avenida Presidio Environmental Management San Clemente, CA 92672 California Dept. of Health Services 850 Marina Parkway, Bldg P, 2nd Floor Mr. James T. Reilly Richmond, CA 94804 Southern California Edison Company San Onofre Nuclear Generating Station Chairman, Board of Supervisors P.O. Box 128 County of San Diego San Clemente, CA 92674-0128 1600 Pacific Highway, Room 335 San Diego, CA 92101 Mr. James D. Boyd, Commissioner California Energy Commission Mark L. Parsons 1516 Ninth Street (MS 31)

Deputy City Attorney Sacramento, CA 95814 City of Riverside 3900 Main Street Brian Katz Riverside, CA 92522 Southern California Edison Company San Onofre Nuclear Generating Station Mr. Gary L. Nolff P.O. Box 128 Assistant Director - Resources San Clemente, CA 92764-0128 City of Riverside 3900 Main Street, 4th Floor Mr. Steve Hsu Riverside, CA 92522 Department of Health Services Radiologic Health Branch Regional Administrator, Region IV MS 7610, P.O. Box 997414 U.S. Nuclear Regulatory Commission Sacramento, CA 95899-7414 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Mr. A. Edward Scherer Southern California Edison Company Mr. Michael J. DeMarco San Onofre Nuclear Generating Station San Diego Gas & Electric Company P.O. Box 128 8315 Century Park Ct. CP21G San Clemente, CA 92674-0128 San Diego, CA 92123-1548 May 2007

REQUEST FOR ADDITIONAL INFORMATION SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 TECHNICAL SPECIFICATIONS CHANGES FOR DEGRADED VOLTAGE INSTRUMENTATION TAC NOS. MD4419 AND MD4420 To support U.S. Nuclear Regulatory Commission (NRC) assessment of the acceptability of the license amendment request with regard to setpoint changes, please provide the following for each setpoint to be added or modified:

1. Setpoint Calculation Methodology: Provide documentation (including sample calculations) of the methodology used for establishing the limiting setpoint (or nominal setpoint) and the limiting acceptable values for the As-Found and As-Left setpoints as measured in periodic surveillance testing as described below. Indicate the related Analytical Limits and other limiting design values (and the sources of these values) for each setpoint.

2. Safety Limit (SL)-Related Determination: Please provide a statement as to whether or not the setpoint is a limiting safety system setting (LSSS) for a variable on which the SL has been placed as discussed in Title 10 of the Code of Federal Regulations (10 CFR), paragraph 50.36(c)(1)(ii)(A). Such setpoints are described as SL-Related in the discussions that follow. In accordance with 10 CFR 50.36(c)(1)(ii)(A), the following guidance is provided for identifying a list of functions to be included in the subset of LSSSs specified for variables on which SLs have been placed as defined in Standard Technical Specifications (STS) Sections 2.1.1, Reactor Core SLs, and 2.1.2, Reactor Coolant System Pressure SLs. This subset includes automatic protective devices in TSs for specified variables on which SLs have been placed that: (1) initiate a reactor trip; or (2) actuate safety systems. As such, these variables provide protection against violating reactor core safety limits, or reactor coolant system pressure boundary safety limits.

Examples of instrument functions that might have LSSSs included in this subset in accordance with the plant-specific licensing basis, are pressurizer pressure reactor trip (pressurized-water reactors), rod block monitor withdrawal blocks, feedwater and main turbine high-water level trip, and end-of-cycle recirculation pump trip (boiling-water reactors).

For each setpoint, or related group of setpoints, that you determined not to be SL-Related, explain the basis for this determination.

3. For setpoints that are determined to be SL-Related: The NRC letter to the Nuclear Energy Institute (NEI) Setpoint Methods Task Force (SMTF) (Reference 3), describes Setpoint-Related TS (SRTS) that are acceptable to the NRC for instrument settings associated with SL-related setpoints. Specifically, Part A of the enclosure to the letter

provides limiting conditions for operations notes to be added to the TS, and Part B includes a checklist of the information to be provided in the TS Bases related to the proposed TS changes.

a. Describe whether and how you plan to implement the SRTS suggested in the September 7, 2005, letter. If you do not plan to adopt the suggested SRTS, then explain how you will ensure compliance with 10 CFR 50.36 by addressing items 3b and 3c, below.

b. As-Found Setpoint evaluation: Describe how surveillance test results and associated TS limits are used to establish operability of the safety system. Show that this evaluation is consistent with the assumptions and results of the setpoint calculation methodology. Discuss the plant corrective action processes (including plant procedures) for restoring channels to operable status when channels are determined to be inoperable or operable but degraded. If the criteria for determining operability of the instrument being tested are located in a document other than the TS (e.g., plant test procedure) explain how the requirements of 10 CFR 50.36 are met.

c. As-Left Setpoint control: Describe the controls employed to ensure that the instrument setpoint is, upon completion of surveillance testing, consistent with the assumptions of the associated analyses. If the controls are located in a document other than the TS (e.g., plant test procedure) explain how the requirements of 10 CFR 50.36 are met.

4. For setpoints that are determined not to be SL-related: Describe the measures to be taken to ensure that the associated instrument channel is capable of performing its specified safety functions in accordance with applicable design requirements and associated analyses. Include in your discussion information on the controls you employ to ensure that the As-Left trip setting after completion of periodic surveillance is consistent with your setpoint methodology. Also, discuss the plant corrective action processes (including plant procedures) for restoring channels to operable status when channels are determined to be inoperable or operable but degraded. If the controls are located in a document other than the TS (e.g., plant test procedure), describe how it is ensured that the controls will be implemented.

REFERENCES:

1. Letter from Timothy J. Kobetz, NRC, to Technical Specifications Task Force (TSTF),

TSTF Traveler 493, Revision 1, Clarify Application of Setpoint Methodology for LSSS Functions, dated December 14, 2006, available on the NRC public website in the Agency Documents Access and Management System (ADAMS), Accession No. ML063450324.

2. NRC Regulatory Issue Summary 2006-17, NRC Staff Position on the Requirements of 10 CFR 50.36, 'Technical Positions,' Regarding Limiting Safety System Settings During Periodic Testing and Calibration of Instrument Channels, dated August 24, 2006, ADAMS Accession No. ML051810077.

3. Letter from Patrick L. Hiland, NRC, to NEI Setpoint Methods Task Force, "Technical Specification for Addressing Issues Related to Setpoint Allowable Values," dated September 7, 2005, ADAMS Accession No. ML052500004.

4. Letter from Bruce A. Boger, NRC, to Alexander Marion, "Instrumentation, Systems, and Automatic Society (ISA) S67.04 Methods for Determining Trip Setpoints and Allowable Values for Safety-Related Instrumentation," dated August 23, 2005, ADAMS Accession No. ML051660447.

5. Letter from James A. Lyons, NRC, to Alex Marion, Nuclear Energy Institute (NEI),

"Instrumentation, Systems, and Automation Society S67.04 Methods for Determining Trip Setpoints and Allowable Values for Safety-Related Instrumentation," dated March 31, 2005, ADAMS Accession No. ML050870008.