ML13100A021

To Amendment Application Number 263 Steam Generator Program

ML13100A021
Person / Time
Site:	San Onofre
Issue date:	04/09/2013
From:	Bauder D Southern California Edison Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
Download: ML13100A021 (11)

Text

~~~~.WI fDr 50"N' Douglas R. Bauder Site Vice President & Station Manager San Onofre Nuclear Generating Station An EDISON INTERNATIONAL Company U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Subject:

Docket No. 50-361 Apr; 1 9, 2013 Supplement 1 to Amendment Application Number 263 Steam Generator Program San Onofre Nuclear Generating Station, Unit 2 10 CFR 50.90

Reference:

Letter from Mr. Peter T. Dietrich (SCE) to NRC dated April 5, 2013, Docket No. 50-361, Amendment Application Number 263 Steam Generator Program, San Onofre Nuclear Generating Station, Unit 2

Dear Sir or Madam:

Southern California Edison (SCE) submitted Amendment Application No. 263 to Docket No. 50-361 (Reference). The Enclosure provides supplemental information on the Technical Specification impact assessment for SONGS Unit 2 operation at 70% Rated Thermal Power in support of the referenced Amendment Application. This supplement does not change the conclusions reached in the No Significant Hazards Consideration section of the Amendment Application and therefore, the No Significant Hazards Consideration is still applicable.

Should you have any questions, or require additional information, please contact Mr. Mark Morgan, Licensing Lead, at (949) 368-6745.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on 4/q/~/3 (Date)

P.O. Box 128 San Clemente, CA 92672 (949) 368-9275 PAX 89275 Fax: (949) 368-9881 Doug.Bauder@sce.com Sincerely,

Document Control Desk April 9, 2013

Enclosure:

Technical Specification Impact Assessment for SONGS Unit 2 Operation at 70% Power cc:

A. T. Howell III, Regional Administrator, NRC Region IV R. Hall, NRC Project Manager, SONGS Units 2 and 3 B. Benney, NRC Project Manager, SONGS Units 2 and 3 G. G. Warnick, NRC Senior Resident Inspector, SONGS Units 2 and 3 S. Y. Hsu, California Department of Public Health, Radiologic Health Branch

ENCLOSURE Technical Specification Impact Assessment for SONGS Unit 2 Operation at 70% Power

TECHNICAL SPECIFICATION IMPACT ASSESSMENT FOR OPERATION AT 70% POWER SONGS Unit2 Description TS LCO, Applicability, Actions, &

TS Change Tech. Spec.

Surveillance Requirements Impact Required?

NOTES:

(1) Power dependency is defined as the Technical Specification LCO, Applicability, Action Statement, or Surveillance Requirement containing a reference to a specific power level or a requirement that is power dependent. References solely to MODE 1 or MODE 2 are not considered power dependent.

1.1 DEFINITION Power level dependent. Definitions for Rated No Thermal Power and Modes (Table 1.1 -1) are not affected by reduced power operation.

1.2 LOGICAL Not power level dependent.

No CONNECTORS 1.3 COMPLETION TIME Not power level dependent.

No 1.4 FREQUENCY Not power level dependent.

No 2.0 SAFETY LIMITS Not power level dependent.

No 3.0 LCO AND SR Not power level dependent.

No APPLICABILITY 3.1.1 SHUTDOWN MARGIN Not power level dependent; applicable only to No (SDM) - TAVG > 200 Modes 3 and 4.

DEGF 3.1.2 SHUTDOWN MARGIN Not power level dependent; applicable only to Mode No (SDM) - T AVG s; 200

5.

DEGF 3.1.3 REACTIVITY BALANCE Not power level dependent. Surveillance No Requirement is addressed in RAI 11 (Table 2).

3.1.4 MODERATOR Power level dependent. MTC limits are analyzed as No TEMPERATURE part of the reload analyses. Operation at 70%

COEFFICIENT (MTC) power does not impact the LCO, Applicability, or Actions. Surveillance Requirements are addressed in RAI 11 (Table 2).

3.1.5 CONTROL ELEMENT Power level dependent. The CEA alignment LCO No ASSEMBL Y (CEA) and Surveillance Requirements are independent of ALIGNMENT power. Required actions as per the COLR are to reduce power after CEA deviation for initial power greater than 50% power. Operation at 70% power does not impact required actions.

3.1.6 SHUTDOWN CONTROL Not power level dependent. The shutdown CEAs No ELEMENT ASSEMBL Y are withdrawn from the core at power. No (CEA) INSERTION distinction is made between power levels in Mode 1.

LIMITS 1 of 8

TECHNICAL SPECIFICATION IMPACT ASSESSMENT FOR OPERATION AT 70% POWER SONGS Unit 2 Description TS LCO, Applicability, Actions, &

TS Change Tech. Spec.

Surveillance Requirements Impact Required?

3.1.7 REGULATING CEA Power level dependent. The LCO is dependent on No INSERTION LIMITS power because the CEA insertion COLR requirements are power dependent. The CEA insertion limit Surveillance Requirements remain valid for operation at 70% power. Power dependent insertion limits (POlL) are validated in reload analysis.

3.1.8 PART LENGTH Power level dependent. The LCO is dependent on No CONTROL ELEMENT power because the part length CEA insertion COLR ASSEMBL Y (CEA) requirements are power dependent. The part length INSERTION LIMITS CEA insertion limit Surveillance Requirements remain valid for operation at 70% power. Power dependent insertion limits (POlL) are validated in reload analysis.

3.1.9 BORATION SYSTEMS - Not power level dependent; requirements are the No OPERATING same for all power levels.

3.1.10 BORATION SYSTEMS - Not power level dependent; applicable only to No SHUTDOWN Modes 5 and 6.

3.1.11 Not Used N/A No 3.1.12 SPECIAL TEST Not power level dependent; applicable only to No EXCEPTION - LOW Modes 2 and 3.

POWER PHYSICS TESTING 3.1.13 SPECIAL TEST Power level dependent. The listed LCOs may be No EXCEPTION - AT suspended provided thermal power is < 85% and POWER PHYSICS linear heat rate does not exceed the limit in the TESTING COLR. Operation at 70% power does not impact the LCO, Applicability, Actions or Surveillance Requirements.

3.1.14 SPECIAL TEST Power level dependent. The listed LCOs may be No EXCEPTION -

suspended provided certain CEA criteria, and LHR REACTIVITY and DNBR do not exceed COLR limits. Operation at COEFFICIENT 70% power does not impact compliance with this TESTING specification.

3.2.1 LINEAR HEAT RATE Power level dependent. LHR limit is validated in No (LHR) reload analysis. Operation at 70% power does not impact compliance with this specification.

3.2.2 PLANAR RADIAL Power level dependent. Operation at 70% power No PEAKING FACTORS does not impact the LCO, Applicability, or Actions.

(Fxy)

Surveillance Requirement is addressed in RAI 11 (Table 2).

3.2.3 AZIMUTHAL POWER Power level dependent. Operation at 70% power No TILT (Tq) does not impact the LCO, Applicability, Actions or Surveillance Requirements. Surveillance Requirement 3.2.3.3 is addressed in RAI 11 (Table 2).

2 of 8

TECHNICAL SPECIFICATION IMPACT ASSESSMENT FOR OPERATION AT 70% POWER SONGS Unit 2 Description TS LCO, Applicability, Actions, &

TS Change Tech. Spec.

Surveillance Requirements Impact Required?

3.2.4 DEPARTURE FROM Power level dependent. Four methods are specified No NUCLEATE BOILING for maintaining DNBR. A power dependency is RATIO (DNBR) specified in the COLR. Operation at 70% power does not impact the LCO, Applicability, Actions or Surveillance Requirements. Operation at 70%

power does not change the requirements of the COLR.

3.2.5 AXIAL SHAPE INDEX Power level dependent. Operation at 70% power No (ASI) does not impact the LCO, Applicability, Actions or Surveillance Requirements. Operation at 70%

power does not change the requirements of the COLR.

3.3.1 REACTOR Power level dependent. RPS trip setpoints are No PROTECTIVE SYSTEM validated in reload analysis. Operation at 70%

(RPS) power does not impact the LCO, Applicability, INSTRUMENTATION -

Actions or Surveillance Requirements. Surveillance OPERATING Requirements 3.3.1.2, 3.3.1.5 and 3.3.1.11 are addressed in RAI 11 (Table 2).

3.3.2 REACTOR Not power level dependent; applicable only to No PROTECTIVE SYSTEM Modes 3, 4 and 5.

(RPS)

INSTRUMENTATION -

SHUTDOWN 3.3.3 CONTROL ELEMENT Not power level dependent; requirements are the No ASSEMBLY same for all power levels.

CALCULATORS 3.3.4 REACTOR Not power level dependent; requirements are the No PROTECTIVE SYSTEM same for all power levels.

(RPS) LOGIC AND TRIP INITIAION 3.3.5 ENGINEERED SAFETY Not power level dependent; requirements are the No FEATURES same for all power levels.

ACTUATION SYSTEM (ESFAS)

INSTRUMENTATION 3.3.6 ENGINEERED SAFETY Not power level dependent; requirements are the No FEATURES same for all power levels.

ACTUATION SYSTEM (ESFAS) LOGIC AND MANUAL TRIP 3.3.7 DIESEL GENERATOR Not power level dependent; requirements are the No (DG) -

same for all power levels.

UNDERVOLTAGE START 3.3.8 CONTAINMENT Not power level dependent; requirements are the No PURGE ISOLATION same for all power levels.

SIGNAL (CPIS) 3 of 8

TECHNICAL SPECIFICATION IMPACT ASSESSMENT FOR OPERATION AT 70% POWER SONGS Unit 2 Description TS LCO, Applicability, Actions, &

TS Change Tech. Spec.

Surveillance Requirements Impact Required?

3.3.9 CONTROL ROOM Not power level dependent; requirements are the No ISOLATION SIGNAL same for all power levels.

(CRIS) 3.3.10 Not Used NIA No 3.3.11 POST ACCIDENT Not power level dependent; requirements are the No MONITORING (PAM) same for all power levels.

INSTRUMENTATION 3.3.12 REMOTE SHUTDOWN Not power level dependent; requirements are the No SYSTEM same for all power levels.

3.3.13 SOURCE RANGE Not power level dependent; applicable only to No MONITORING Modes 3, 4 and 5.

CHANNELS 3.4.1 RCS DNB PRESSURE, Power level dependent. Power dependency is as No TEMPERATURE AND specified in the COLR. RCS operating limits are FLOW LIMITS analyzed as part of the reload analyses. RCS flow limit is addressed in RAI 12. Operation at 70%

power does not impact the LCO, Applicability, Actions or Surveillance Requirements. Operation at 70% power does not change the requirements of the COLR.

3.4.2 RCS MINIMUM Power level dependent. Operation at 70% power No TEMPERATURE FOR does not impact the LCO, Applicability, Actions or CRITICALITY Surveillance Requirements.

3.4.3 RCS PRESSURE AND Not power level dependent; requirements are the No TEMPERATURE (PIT) same for all power levels.

LIMITS 3.4.3.1 PRESSURIZER Not power level dependent; requirements are the No HEATUPAND same for all power levels.

COOLDOWN LIMITS 3.4.4 RCS LOOPS - MODES Not power level dependent; requirements are the No 1 AND 2 same for all power levels.

3.4.5 RCS LOOPS - MODES Not power level dependent; applicable only to Mode No 3

3.

3.4.6 RCS LOOPS - MODES Not power level dependent; applicable only to Mode No 4

4.

3.4.7 RCS LOOPS - MODES Not power level dependent; applicable only to Mode No 5, LOOPS FILLED

5.

3.4.8 RCS LOOPS - MODES Not power level dependent; applicable only to Mode No 5, LOOPS NOT FILLED 5.

3.4.9 PRESSURIZER Not power level dependent; requirements are the No same for all power levels.

3.4.10 PRESSURIZER Not power level dependent; requirements are the No SAFETY VALVES same for all power levels.

3.4.11 Not used NIA No 4 of 8

TECHNICAL SPECIFICATION IMPACT ASSESSMENT FOR OPERATION AT 70% POWER SONGS Unit 2 Description TS LCO, Applicability, Actions, &

TS Change Tech. Spec.

Surveillance Requirements Impact Required?

3.4.12.1 LOW TEMPERATURE Not power level dependent; applicable only to No OVERPRESSURE Modes 4, 5, and 6.

PROTECTION (L TOP)

SYSTEM RCS TEMPERATURE <=

PTLR LIMIT 3.4.12.2 LOW TEMPERATURE Not power level dependent; applicable only to Mode No OVERPRESSURE

4.

PROTECTION (L TOP)

SYSTEM RCS TEMPERATURE>

PTLR LIMIT 3.4.13 RCS OPERATIONAL Not power level dependent; requirements are the No LEAKAGE same for all power levels.

3.4.14 RCS PRESSURE Not power level dependent; requirements are the No ISOLATION VALVE same for all power levels.

(PIV) LEAKAGE 3.4.15 RCS LEAKAGE Not power level dependent; requirements are the No DETECTION same for all power levels.

INSTRUMENTATION 3.4.16 RCS SPECIFIC Power level dependent. Action A.1 and Figure No ACTIVITY 3.4.16-1 are addressed in RAI 11. Operation at 70% power does not impact the LCO, Applicability, remaining Actions, or Surveillance Requirements.

3.4.17 STEAM GENERATOR Not power level dependent; requirements are the No (SG) TUBE INTEGRITY same for all power levels.

3.5.1 SAFETY INJECTION Not power level dependent; requirements are the No TANKS (SITs) same for all power levels.

3.5.2 ECCS - OPERATING Not power level dependent; requirements are the No same for all power levels.

3.5.3 ECCS - SHUTDOWN Not power level dependent; applicable only to No Modes 3 and 4.

3.5.4 REFUELING WATER Not power level dependent; requirements are the No TANK (RWT) same for all power levels.

3.5.5 TRISODIUM Not power level dependent; requirements are the No PHOSPHATE (TSP) same for all power levels.

3.6.1 CONTAINMENT Not power level dependent; requirements are the No same for all power levels.

3.6.2 CONTAINMENT AIR Not power level dependent; requirements are the No LOCKS same for all power levels.

3.6.3 CONTAINMENT Not power level dependent; requirements are the No ISOLATION VALVES same for all power levels.

3.6.4 CONTAINMENT Not power level dependent; requirements are the No PRESSURE same for all power levels.

5 of 8

TECHNICAL SPECIFICATION IMPACT ASSESSMENT FOR OPERATION AT 70% POWER SONGS Unit 2 Description TS LCO, Applicability, Actions, &

TS Change Tech. Spec.

Surveillance Requirements Impact Required?

3.6.5 CONTAINMENT AIR Not power level dependent; requirements are the No TEMPERATURE same for all power levels.

3.6.6.1 CONTAINMENT SPRAY Not power level dependent; requirements are the No AND COOLING same for all power levels.

SYSTEMS 3.6.6.2 CONTAINMENT Not power level dependent; applicable only to Mode No COOLING SYSTEM

4.

3.6.7 Not Used N/A No 3.6.8 CONTAINMENT DOME Not power level dependent; requirements are the No AIR CIRCULATORS same for all power levels.

3.7.1 MAIN STEAM SAFETY Power level dependent. Table 3.7.1-1 is validated No VALVES (MSSVs) as part of the reload analyses. Operation at 70%

power does not impact the LCO, Applicability, Actions, or Surveillance Requirements.

3.7.2 MAIN STEAM Not power level dependent; requirements are the No ISOLATION VALVES same for all power levels.

(MSIVs) 3.7.3 MAIN FEEDWATER Not power level dependent; requirements are the No ISOLATION VALVES same for all power levels.

(MFIVs) 3.7.4 ATMOSPHERIC DUMP Not power level dependent; requirements are the No VALVES (ADVs) same for all power levels.

3.7.5 AUXILIARY Not power level dependent; requirements are the No FEEDWATER (AFW) same for all power levels.

SYSTEM 3.7.6 CONDENSATE Not power level dependent; requirements are the No STORAGE TANK (CST) same for all power levels.

3.7.7 COMPONENT Not power level dependent; requirements are the No COOLING WATER same for all power levels.

(CCW) SYSTEM 3.7.7.1 COMPONENT Not power level dependent; requirements are the No COOLING WATER same for all power levels.

(CCW) SAFETY RELATED MAKEUP SYSTEM 3.7.8 SALTWATER COOLING Not power level dependent; requirements are the No SYSTEM (SWC) same for all power levels.

3.7.9 Not Used N/A No 3.7.10 EMERGENCY CHILLED Not power level dependent; requirements are the No WATER (ECW) same for all power levels.

3.7.11 CONTROL ROOM Not power level dependent; requirements are the No EMERGENCY AIR same for all power levels.

CLEANUP SYSTEM (CREACS) 6 of 8

TECHNICAL SPECIFICATION IMPACT ASSESSMENT FOR OPERATION AT 70% POWER SONGS Unit2 Description TS LCO, Applicability, Actions, &

TS Change Tech. Spec.

Surveillance Requirements Impact Required?

3.7.12 - 3.7.15 Not Used N/A No 3.7.16 FUEL STORAGE POOL Not power level dependent.

No WATER LEVEL 3.7.17 FUEL STORAGE POOL Not power level dependent.

No BORON CONCENTRATION 3.7.18 SPENT FUEL Not power level dependent.

No ASSEMBL Y STORAGE 3.7.19 SECONDARY Not power level dependent; requirements are the No SPECIFIC ACTIVITY same for all power levels.

3.8.1 AC SOURCES-Not power level dependent; requirements are the No OPERATING same for all power levels.

3.8.2 AC SOURCES-Not power level dependent.

No SHUTDOWN 3.8.3 DIESEL FUEL OIL, Not power level dependent; requirements are the No LUBE OIL, AND same for all power levels.

STARTING AIR 3.8.4 DC SOURCES-Not power level dependent; requirements are the No OPERATING same for all power levels.

3.8.5 DC SOURCES-Not power level dependent.

No SHUTDOWN 3.8.6 BATTERY Not power level dependent; requirements are the No PARAMETERS same for all power levels.

3.8.7 INVERTERS -

Not power level dependent; requirements are the No OPERATING same for all power levels.

3.8.8 INVERTERS -

Not power level dependent.

No SHUTDOWN 3.8.9 DISTRIBUTION Not power level dependent; requirements are the No SYSTEMS -

same for all power levels.

OPERATING 3.8.10 DISTRIBUTION Not power level dependent.

No SYSTEMS -

SHUTDOWN 3.9.1 BORON Not power level dependent; applicable only to Mode No CONCENTRATION

6.

3.9.2 NUCLEAR Not power level dependent; applicable only to Mode No INSTRUMENTATION

6.

3.9.3 CONTAINMENT Not power level dependent.

No PENETRATIONS 3.9.4 SHUTDOWN COOLING Not power level dependent; applicable only to Mode No (SDC) AND COOLANT

6.

CIRCULATION - HIGH WATER LEVEL 7 of 8

TECHNICAL SPECIFICATION IMPACT ASSESSMENT FOR OPERATION AT 70% POWER SONGS Unit 2 Description TS LCO, Applicability, Actions, &

TS Change Tech. Spec.

Surveillance Requirements Impact Required?

3.9.5 SHUTDOWN COOLING Not power level dependent; applicable only to Mode No (SDC) AND COOLANT

6.

CIRCULATION - LOW WATER LEVEL 3.9.6 REFUELING WATER Not power level dependent.

No LEVEL 4.1 DESIGN FEATURES --

Not power level dependent.

No SITE 4.2 REACTOR CORE Not power level dependent.

No 4.3 FUEL STORAGE Not power level dependent.

No 5.1 RESPONSIBILITY Not power level dependent.

No 5.2 ORGANIZATION Not power level dependent.

No 5.3 UNIT STAFF Not power level dependent.

No QUALIFICATION 5.4 TECHNICAL Not power level dependent.

No SPECIFICATION (TS)

BASES CONTROL 5.5 PROCEDURES, Power level dependent. License Amendment Yes PROGRAMS, AND Request PCN 602 requests that Technical MANUALS Specification 5.5.2.11.b.1 be revised to add a footnote to require that compliance with the steam generator structural integrity performance criterion (SIPC) be demonstrated up to 70% rated thermal power.

Remaining procedures, programs and manuals addressed in Section 5.5 are not power level dependent.

5.6 SAFETY FUNCTION Not power level dependent.

No DETERMINATION PROGRAM (SFDP) 5.7 REPORTING Not power level dependent. Technical Specification No REQUIREMENTS 5.7.1.5 requires Core Operating Limits Report safety analyses to address operation at Rated Thermal Power. Refer to License Amendment Request PCN 602 commitment regarding Technical Specification 5.7.2.c Steam Generator Program Special Report. Remaining reporting requirements addressed in Section 5.7 are not impacted.

5.8 HIGH RADIATION Not poWer level dependent.

No AREA 8 of 8