ML082210113
| ML082210113 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/12/2008 |
| From: | Kalyanam N NRC/NRR/ADRO/DORL/LPLIV |
| To: | Ridenoure R Southern California Edison Co |
| Kalyanam N, NRR/DLPM, 415-1480 | |
| References | |
| GL-08-001, TAC MD7876, TAC MD7877 | |
| Download: ML082210113 (7) | |
Text
August 12, 2008 Mr. Ross T. Ridenoure 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 -
GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS, PROPOSED ALTERNATIVE COURSE OF ACTION (TAC NOS. MD7876 and MD7877)
Dear Mr. Ridenoure:
On January 11, 2008, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
By letter dated May 15, 2008, Southern California Edison (SCE), the licensee, submitted a 3-month response to GL 2008-01 for San Onofre Nuclear Generating Station, Units 2 and 3 (SONGS 2 and 3). The NRC staff assessment of the responses for SONGS 2 and 3 is contained in Enclosure 1.
The NRC staff reviewed the licensees proposed alternative course of action and the associated basis for acceptance and concluded that for the SONGS, with the exception of the clarifications and associated requests discussed in Enclosure 1, your proposed alternative course of action related to your 9-month initial response is acceptable. However, the NRC staff requests you submit a 3-month supplemental response to revise your proposed alternative course of action related to your 9-month supplemental (post outage) response for SONGS 2 and 3 as described in Enclosure 1. This letter allows the licensee to implement its proposed alternative course of action for its 9-month initial response, provided that, implementation is consistent with the clarifications and associated requests discussed in Enclosure 1.
If you have any questions regarding this letter, please feel free to 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:
As stated cc w/encl: See next page
The NRC staff reviewed the licensees proposed alternative course of action and the associated basis for acceptance and concluded that for the SONGS, with the exception of the clarifications and associated requests discussed in Enclosure 1, your proposed alternative course of action related to your 9-month initial response is acceptable. However, the NRC staff requests you submit a 3-month supplemental response to revise your proposed alternative course of action related to your 9-month supplemental (post outage) response for SONGS 2 and 3 as described in Enclosure 1. This letter allows the licensee to implement its proposed alternative course of action for its 9-month initial response, provided that, implementation is consistent with the clarifications and associated requests discussed in Enclosure 1.
If you have any questions regarding this letter, please feel free to 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:
As stated cc w/encl: See next page DISTRIBUTION:
PUBLIC RidsOgcRp LPL4 R/F RidsAcrsAcnw&mMailCenter RidsNrrDorlLIV RidsRgn4MailCenter RidsNrrLAGLappert DBeaulieu, DPR/PGCB RidsNrrPMNKalyanam SSun, DSS/SRXB RidsNrrDorlDPR WLyon, DSS/SRXB
- See prior concurrence ADAMS Accession Number: ML082210113 NRR-106, Log #1930 OFFICE LPL4/PM LPL/4/LA PGCB:BC*
DSS/DD*
LPL4/BC (A)
LPL/4/PM NAME NKalyanam GLappert MMurphy JWermeil JDonohew NKalyanam DATE 8/12/08 8/12/08 8/12/08 8/12/08 8/12/08 8/12/08 OFFICIAL RECORD COPY U.S. NUCLEAR REGULATORY COMMISSION STAFF ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 SOUTHERN CALIFORNIA EDISON COMPANY SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3 DOCKET NOS. 50-361 and 50-362 1.0 Background On January 11, 2008, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
2.0 Licensees Proposed Alternative Course of Action By letter dated May 15, 2008, Southern California Edison (SCE, the licensee), submitted a 3-month response to GL 2008-01 for San Onofre Nuclear Generating Station, Units 2 and 3 (SONGS 2 and 3). The licensee indicated that it could not complete, within the requested 9-month period, the necessary walkdowns because of one or more of the following reasons:
(1) the restrictions on removal of insulation from piping on operating systems due to equipment qualification concerns; (2) ALARA considerations for entry into radiation areas; and (3) the requirements to erect scaffolding which mat affect equipment operability.
As an alternative course of action, SCE stated that it would submit a response within nine months of the date of the GL providing the results of the evaluation, identifying requiring confirmatory walkdowns that have not been completed, and provide the schedule for their completion. SCE concluded that the alternative course of action is acceptable, based on the adequacy of the current design, additional vent locations added as needed, plant surveillance and analysis, and the results of previous system inspections.
3.0 NRC Staff Assessment The NRC staff finds that for SONGS 2 and 3, with the exception of the clarifications and associated requests discussed below, the licensees proposed alternative course of action related to its 9-month initial response is acceptable. This is based on current designs, plant surveillance and analysis, and inspection results associated with managing gas accumulation at SONGS. However, the NRC staff requests that the licensee submit a 3-month supplemental response for SONGS 2 and 3 to revise its proposed alternative course of action related to its 9-month supplemental response as described below.
The NRC staff notes the following examples where the licensees 3-month submittal dated May 15, 2008, does not clearly describe the content and/or schedule for the 9-month submittals:
(1)
Although the licensee plans to include the results of its evaluation in its 9-month response, it does not state that its evaluation will include the reviews of the licensing basis, the design drawings, and the testing and system operating procedures, and the corrective actions resulting from the walkdowns that are completed before October 11, 2008, in its 9-month response.
(2)
While the licensee indicated that in the 9-month response, it would identify the required confirmatory walkdowns that have not been completed, and provide the schedule for their completion, it did not state when the remaining walkdowns that were not completed by October 11, 2008, would be completed and results will be submitted to the NRC. Since the design details and as-built configurations may be different in each of the two units, the NRC staff requests the licensee to provide a separate 9-month supplemental response for each of the two units.
The NRC staff requests that the licensee submit the information requested in the GL as follows:
(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the next refueling outages for SONGS 2 and 3, provide all the information requested by the GL to the NRC by October 11, 2008. The NRC staff finds that licensees plan regarding the 9-month initial response is acceptable.
(2) 9-Month Supplemental (Post-Outage) Submittals - Except for the long-term items described below, provide all the remaining information requested by the GL for the subject systems to the NRC within 90 days following completion of the first refueling outages that initiate from October 11, 2008, for each of SONGS 2 and 3. The NRC staff requests the licensee to submit a 3-month supplemental response to provide a revised commitment that meets the request of the 9-month supplemental responses for each of SONGS 2 and 3.
For each of the two submittals, (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensees should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
The NRC staff noted that the licensees submittal dated May 15, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.
San Onofre Nuclear Generating Station (June 2008)
Units 2 and 3 cc:
Douglas K. Porter, Esquire Southern California Edison Company 2244 Walnut Grove Avenue Rosemead, CA 91770 Dr. David Spath, Chief Division of Drinking Water and Environmental Management California Dept. of Health Services 850 Marina Parkway, Bldg P, 2nd Floor Richmond, CA 94804 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 General Manager - Resources Riverside Public Utilities City of Riverside, California 3901 Orange Street Riverside, CA 92501 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 Mr. Michael L. De Marco San Diego Gas & Electric Company 8315 Century Park Ct. CP21G San Diego, CA 92123-1548 Resident Inspector San Onofre Nuclear Generating Station 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 California State Liaison Officer Vice Chair and Commissioner California Energy Commission 1516 Ninth Street, MS 31 Sacramento, CA 95814 Mr. Gary Butner Acting Branch Chief Department of Public Health Services Radiologic Health Branch MS 7610, P.O. Box 997414 Sacramento, CA 95899-7414 Vice President and Site Manager Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128 Mr. A. Edward Scherer Director, Nuclear Regulatory Affairs Southern California Edison Company San Onofre Nuclear Generating Station P.O. Box 128 San Clemente, CA 92674-0128