ML110840627

Licensee Slides from 3-24-11 Pre-Submittal Meeting with Southern California Edison on Improved Technical Specification Upgrade

ML110840627
Person / Time
Site:	San Onofre
Issue date:	03/24/2011
From:	Southern California Edison Co
To:	Office of Nuclear Reactor Regulation
Hall, J R, NRR/DORL/LPL4, 301-415-4032
References
TAC ME5807, TAC ME5808
Download: ML110840627 (23)

Text

{{#Wiki_filter:SOUTHERN CALIFORNIA EDISON ~ An EDISON INTERNATIONAL Company NRC-SONGS Pre-Submittal Conference IMPROVED TECHNICAL I' SPECIFICATION UPGRADE March 24, 2011 1.l'ading {h <..* \\,\\'a\\ in Fil-cu'icit\\, I 1

Agenda I. Introduction Purpose of Meeting NRC, SCE and Excel Services NRC, SCE and Excel Services II. Project Description Overview Scope Phases Initial Planning LAR Development Support of NRC Review and Approval Implementation Current TS LAR Status III. Discussion Topics CTS LAR Incorporation Licensee Identified Beyond Scope Items Accelerated Licensing Review Process NRC Resources and 2011 Schedule Support IV. TS Upgrade Operational Focus Current TS Upgrade Benefits V. Summary 1Il 1'~h: Clrlcit \\ 2

I. Introduction Purpose of Meeting: Provide an update on our progress regarding the impending submittal of SONGS ITS Upgrade LAR and discuss the review process and schedule Attendees: SONGS Jason Janke, Operations Shift Manager Linda Conklin, Licensing Manager Mark Morgan, SONGS Licensing Technical Leader Rene Vogt-Lowell, TS Implementation Project Manager EXCEL Personnel Ray Schiele, Project Manager EXCEL Jerry Jones, EXCEL ITS Specialist 1.t...'~Hli n !-{ lhe \\\\'a\\ in I ;.Ie([ririt\\ I 3

II. Project Description Overview

• Current TS (CTS) based on pre-Rev 0 NUREG Developed by SCE and EXCEL in parallel with the original NU REG 1432 and were submitted to the NRC before Rev 0 was issued.

Licensee Control Specifications (LCS) were created from the specifications removed from the custom TS Identified need to bring TS and LCS up to today's standard ITS Upgrade: Key Station priority for 2011 and 2012 Significant Resource Expenditure (CLB, Procedures, Training) Key Benefits

• I mproved Safety / Operational Performance
• Eased Admin Burdens
• Improved Regulatory Performance
• Consistency with other sites I.l*'h.ling tht, \\\\ '~\\ ~ in I :.h:cu*iri{\\

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II. Project Description (continued) Scope

• Adopt NUREG 1432 Rev 3.0
• Adopt approved Tech Spec Task Force (TSTF) travelers since Rev 3.0 was issued
• Minimize differences between ISTS and SONGS TS, except where design differences dictate
• Maintain CTS in areas where specific NRC approval was previously granted
• Combine U2 and U3 TS into One Document
• Re-write LCS (Licensee Controlled Specifications) to TRM (Technical Requirements Manual) format using 10CFR50.59 l.cndinu thl' \\\\ ':1\\ ill Fh:([ril:i(\\

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II. Project Description (continued) Phases

• Initial Planning - complete
• LAR Development - nearly complete
• Support of NRC Review and Approval
• Implementation

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II. Project Description (continued) Phase: LAR Development Approach The development of the SONGS ITS Upgrade LAR, followed both the NEI Conversion Guidance Document and the SONGS LAR process. l.l*~ll. li n g th e.: \\'\\':1\\ in Fln:rriri t\\ I 7

II. Project Description (continued) Phase: LAR Development (continued) Approved Travelers Adopted not in Current NRC Website Electronic File TSTF-412 TSTF-422 TSTF-425 TSTF-448 TSTF-471 TSTF-475 TSTF-486 TSTF-487 Provide Actions for One Steam Supply to Turbine Driven AFW/EFW Pump Inoperable Change in Technical Specification End State (CE-NPSD-1186) Relocate Surveillance Frequency to License Control Program - RITSTF Initiative 5b Control Room Habitability (already incorporated into CTS) Eliminate use of term CORE ALTERATIONS in ACTIONS and Notes Control Rod Notch testing Frequency and SRM Insert Control Rod Action (affects ITS 1.4 only) Revise MTC Surveillance for Startup Test Activity Reduction (STAR) Relocate DNB parameters to COLR (already incorporated into CTS) I,C'H.ling tlH.: \\'Cn in I :.k n rit:jl\\ I 8

II. Proiect Description (continued) Phase: LAR Development (continued) Approved Travelers Adopted not in Current NRC Website Electronic File TSTF-490 Deletion of E-bar Definition and Revision to RCS Specific Activity Tech Spec TSTF-491 Removal of Main Steam and Main Feedwater Valve Isolation Times from Technical Specifications TSTF-493 Clarify Application of Setpoint Methodology for LSSS Functions

• TSTF-497 Limit Inservice Testing Program SR 3.0.2 Application to Frequencies of 2 years or less TSTF-501 Relocate Stored Fuel Oil and Lube Oil Volume Values to TRM TSTF-511 Eliminate Working Hour Restrictions from TS 5.2.2 to support Compliance with 10 CFR Part 26 (already incorporated into CTS)

TSTF-513 Leakage Detection System changes (CTS 3.4.15) I.l'ading- {he \\\\ fa ~ in I~ h:(tricit\\ 9

II. Project Description (continued) Phase: LAR Development (continued) Licensing Package Composition

• Current Tech Spec markup
• Discussion of Changes
• ISTS and ISTS Bases markup
• Justification for Deviation from the ISTS
• No Significant Hazard Consideration
• Any Supporting Information needed l.l';hJillg lhl' "\\'a\\ in Fil-c(rici(\\'

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II. Project Description (continued) Phase: LAR Development (continued) Reformatting LCS to TRM

• Some SONGS CTS details were relocated to the TRM
• Some LCS details were placed into the SONGS ITS (e.g., 1ST Program details)
• RIS 2005-20 enhancements (e.g., "functional" vs "ope rable")
• Removal of unnecessary Shutdown Requirements (e.g. LCS 3.7.113.1 Appendix R)

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II. Project Description (continued) Current TS LAR Status Discussion of Possible Enforcement Discretion

• TS upgrade Submittal late April
• TSTF-513 (RCS Leakage Monitoring In Containment) LAR cutoff early May EGM-09-001 Ongoing Enforcement Discretion requires submittal of a LAR adopting TSTF-513 within 4 months of Notice of Availability.

NRC will consider extending the four month period, on a case-by-case basis, with adequate justification from the licensee.

• SONGS CTS differs significantly from the TSTF
• Parallel TSTF-LARs would require redundant effort and review I.l'adi ng tht' \\X 'a\\ in I :,kc£ricit\\,

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I. Discussion Topics

1. CTS LAR Approach

2. Licensee Identified Beyond Scope Items

3. Accelerated Licensing Review Process

4. NRC Resources and 2011 Schedule Support I.l'ilding tht' \\\\':1\\ in Fkcrriclt\\.

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III. Discussion Topics (continued) 1. CTS LAR Incorporation

• Attempted to minimize other LARs during ITS review period
• However, there are several LARs in process at this time I,l';lding,hl' \\\\ '~l\\ in I;.ienriri t\\.

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III. Discussion Topics (continued) License Amendment Requests LAR Topic Forecast Cyber Security LAR RAI responses N/A Technical Specification Upgrade Project 4/29/11 RWST Purification Loop AREVA Fuel Test Assembly Permanent Exemption NFPA 805 2011 6/30/11 6/29/11 ECW/CCW 2-Hour Swap Allowance for flow path andAC Power 3011 New Emergency Room Cooler Specification 3011 Low Power Recapture LAR 4011 Resubmit FHA LAR TBD Comments License change under Review. No Impact to TS Impact to all Sections No expected impact to TS Impact to Section 4.1 Impact to License Impact to Section 3.7 Impact to Section 3.7 Impact to License Impact to several subparts of Chapter 3 I.l'.ldi ng lht* \\,\\ 'a\\ in FI c.:((1"l(il \\ I 15

III. Discussion Topics (continued)

2. Licensee Identified Beyond Scope Items

• CEA Rod Position Specification (from CTS SRs 3.1.5.2 and 3.1.5.4) (Adopted from NUREG 1431)
• Update DC Sources and Battery Parameter Specifications (CTS 3.8.4 and 3.8.6) to delete removed equipment (1260 amp hour batteries)

(Admin cleanup)

• Correct Control Room Isolation Signal high radiation setpoint (e.g., Monitor reads in JJCi/cc but CTS in cpm)

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III. Discussion Topics (continued)

3. Accelerated Licensing Review Process Objectives:

• Single supplement prior issuance of the SER
• Reduce licensee cost
• Reduce required NRC resources
• Reduce required amount of formal correspondence 17 I.l * 'l din I ~ tlH: \\'\\ ';1\\
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I. Discussion Topics (continued)

4. NRC Resources and 2011 Schedule Support

• NRC Team Lead/Project Manager
• Acceptance review approach (LIC-109 ?)
• NRC Team performing SONGS LAR Reviews
• Familiarity/Navigation orientation will be available on use of Q & A database, as needed
• Development of a project schedule and project milestones.

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IV. TS Upgrade Operational Focus Current TS Do not consistently follow the usage rules Examples: CCW backup N2 in TS 3.7.7 CCW seismic makeup in TS 3.7.7.1 Contain Conflicting Actions Example: TS 3.6.3 actions, Containment Isolation valves Contain lack of guidance or ambiguity in some Tech Specs Example: New TS 3.0.8 Snubbers New TS 3.7.12 CREATCS Above issues potentially result in non-conservative/unnecessary unit shutdowns resulting from incorrect calls due to an inconsistently written Tech Spec. 1.cadin,g th e.: \\\\ '~1\\. in Fknricit " 20

IV. TS Upgrade Operational Focus (continued) Upgrade Benefits Clear, unambiguous and consistent guidance at all times for on-shift Operators

• Improved Safety
• Improved Operational Performance
• Improved Regulatory Performance
• Improved ability to discuss TS Issues with other plants (currently not practical)
• Upgrade SONGS TS to the current Industry Standards 1.l*ading-the \\\\ '~l\\ in Flecrrl(i(\\.'

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v. Summary

• SONGS Current TS already in ITS format
• Adopting the latest NUREG 1432 with travelers
• ITS Upgrade LAR Submittal Forecast 4/29/2011
• TSTF-513 Enforcement Discretion Pathway
• Anticipate the same Accelerated Licensing Review Process used for past 5 conversions
• Implementation activities in parallel with NRC review to realize "Upgrade" benefits ASAP I.t.:ading lh e.: \\, 'a\\ in Fl <.:c( rici(\\'

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