ML111170872
| ML111170872 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 04/29/2011 |
| From: | Markley M Plant Licensing Branch IV |
| To: | Peter Dietrich Southern California Edison Co |
| Hall, J R, NRR/DORL/LPL4, 301-415-4032 | |
| References | |
| TAC ME6090, TAC ME6091, EA-2011-105 | |
| Download: ML111170872 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 29, 2011 EA-2011-105 Mr. Peter T. Dietrich 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 AN EXTENSION OF ENFORCEMENT DISCRETION REGARDING OPERABILITY OF CONTAINMENT ATMOSPHERE GASEOUS RADIOACTIVITY MONITORS (TAC NOS. ME6090 AND ME6091)
Dear Mr. Dietrich:
By letter dated April 22, 2011 (Agencywide Document Access and Management System (ADAMS) Accession No. ML11115A097), the Southern California Edison Company (SCE) requested an extension of the current enforcement discretion authorized in the Nuclear Regulatory Commission's (NRC's) Enforcement Guidance Memorandum (EGM) 09-001, "Dispositioning Violations of NRC Requirements for Operability of Gaseous Monitors for Reactor Coolant System Leakage Detection," dated January 30, 2009 (ADAMS Accession No. ML090300467), for the San Onofre Nuclear Generating Station (SONGS), Units 2 and 3. In EGM 09-001, the NRC granted enforcement discretion to licensees of nuclear power plants with design features that rely, in part, on containment atmosphere gaseous radioactivity monitoring systems for reactor coolant system (RCS) leakage detection.
EGM 09-001 describes the basis for the existing enforcement discretion. Gaseous radioactivity monitors provide an indirect means to measure RCS leakage by detecting the resulting airborne radioactivity corresponding to an assumed concentration of radioactivity in the ReS. Improved fuel performance has reduced the radioactivity concentration in the RCS for some plants, thereby impacting the response time of the gaseous monitors for detecting RCS leakage. This could affect the operability of the monitors, and require the plant to enter a Technical Specification (TS) Limiting Condition for Operation. In EGM 09-001, the NRC staff determined that enforcement discretion is appropriate for this issue, as the monitors' longer response times are of very low safety significance; there are redundant and diverse means available to detect RCS leakage; and there are multiple emergency core cooling systems designed to mitigate loss of coolant accidents.
EGM 09-001 provides for the continuation of enforcement discretion for those licensees planning to resolve the issue by submitting a license amendment request (LAR). In accordance with the EGM, enforcement discretion will remain in effect for up to 4 months from the date that the NRC staff publishes the Notice of Availability (NOA) of a model LAR to address this issue, for those licensees submitting a conforming LAR. The NOA was published in the Federal Register on January 3, 2011 (76 FR 189); therefore, licensees have until May 3, 2011, to submit
P. Dietrich
-2 an LAR consistent with the model provided in Technical Specification Task Force (TSTF)
Traveler TSTF-513, Revision 3, "Revise PWR [Pressurized-Water Reactor] Operability Requirements and Actions for RCS Leakage Instrumentation." Enforcement discretion would remain in effect for those licensees submitting a conforming LAR until the NRC staff takes final action on the amendment request. The EGM further states that the NRC will consider extending the enforcement discretion beyond the 4-month period, on a case-by-case basis, with adequate justification from the licensee.
In the April 22, 2011, request for extension of the enforcement discretion, SCE stated that it is preparing a TS conversion for SONGS. Units 2 and 3, which will consist of a comprehensive LAR, incorporating the adoption of multiple TSTFs, including TSTF-513, Revision 3. SCE asserted that inclusion of TSTF-513, Revision 3. in the much broader conversion LAR will allow for a more efficient review process, thereby saving NRC and SCE resources. We understand from prior public meetings on the planned TS conversion that SCE intended to submit the TS conversion LAR prior to May 3, 2011; however, SCE now expects to submit that LAR shortly, but not before that date. SCE has requested that NRC extend the period of enforcement discretion for SONGS until August 3, 2011, to allow additional time for submittal of the comprehensive LAR incorporating TSTF-513, Revision 3.
The NRC staff has reviewed the information provided in SCE's letter dated April 22, 2011, and has determined that SCE has provided sufficient justification for the staff to grant the requested extension of enforcement discretion. The staff agrees that including the changes in TSTF-513, Revision 3, in the much larger TS conversion LAR will result in a more efficient use of NRC and licensee resources, and that the requested 3-month extension is reasonable, compared to the total time the enforcement discretion has been in effect and will remain in effect during the NRC's review of the LAR. Accordingly, provided that SCE submits an LAR consistent with the model in TSTF-513, Revision 3, no later than August 3, 2011, the enforcement discretion authorized in accordance with EGM 09-001 is hereby extended for SONGS, Units 2 and 3, until the NRC staff takes final action on the request.
If you have any questions regarding this matter, please contact the project manager, Randy Hall, at (301) 415-4032.
Sincerely, Michael 1. Markley, Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362 cc: Distribution via Listserv
P. Dietrich
- 2 an LAR consistent with the model provided in Technical Specification Task Force (TSTF)
Traveler TSTF-513, Revision 3, "Revise PWR [Pressurized-Water Reactor] Operability Requirements and Actions for RCS Leakage Instrumentation." Enforcement discretion would remain in effect for those licensees submitting a conforming LAR until the NRC staff takes final action on the amendment request The EGM further states that the NRC will consider extending the enforcement discretion beyond the 4-month period, on a case-by-case basis, with adequate justification from the licensee.
In the April 22, 2011, request for extension of the enforcement discretion, SCE stated that it is preparing a TS conversion for SONGS, Units 2 and 3, which will consist of a comprehensive LAR, incorporating the adoption of multiple TSTFs, including TSTF-513, Revision 3. SCE asserted that inclusion of TSTF-513, Revision 3, in the much broader conversion LAR will allow for a more efficient review process, thereby saving NRC and SCE resources. We understand from prior public meetings on the planned TS conversion that SCE intended to submit the TS conversion LAR prior to May 3, 2011; however, SCE now expects to submit that LAR shortly, but not before that date. SCE has requested that NRC extend the period of enforcement discretion for SONGS until August 3, 2011, to allow additional time for submittal of the comprehensive LAR incorporating TSTF-513, Revision 3, The NRC staff has reviewed the information provided in SCE's letter dated April 22, 2011, and has determined that SCE has provided sufficient justification for the staff to grant the requested extension of enforcement discretion. The staff agrees that including the changes in TSTF-513, Revision 3, in the much larger TS conversion LAR will result in a more efficient use of NRC and licensee resources, and that the requested 3-month extension is reasonable, compared to the total time the enforcement discretion has been in effect and will remain in effect during the NRC's review of the LAR. Accordingly, provided that SCE submits an LAR consistent with the model in TSTF-513, Revision 3, no later than August 3, 2011, the enforcement discretion authorized in accordance with EGM 09-001 is hereby extended for SONGS, Units 2 and 3, until the NRC staff takes final action on the request.
If you have any questions regarding this matter, please contact the project manager, Randy Hall, at (301) 415-4032.
Sincerely, IRA by N.Kalyanam forI Michael T. Markley, Chief Plant licenSing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362 cc: Distribution via Listserv DISTRIBUTION:
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