ML13302A349
| ML13302A349 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/20/1980 |
| From: | Baer R Office of Nuclear Reactor Regulation |
| To: | James Drake, Gilman D San Diego Gas & Electric Co, Southern California Edison Co |
| References | |
| NUDOCS 8004110028 | |
| Download: ML13302A349 (15) | |
Text
D)stribution NRC PDR SHanauer IE(3)
Local PDR JKnight NSIC Docket File RTedesco TIC LWR #2 File RDeYoung ACRS(16)
DFRoss VMoore DBVassallo WKreger Docket Nos SAVarga TMurphy
- 50-362 FJWilliams.
MErnst RLBaer RDenise HRood RHartfield JLee ELD Mr. James H. Drake RMattsonMr. D. W. Gilman Vice President Senior Vice President - Operations Southern California Edison Company San Diego Gas and Electric Company 2244 Walnut Grove Avenue 101 Ash Street P. 0. Box 800 P. 0. Box 1831 Rosemead, California 91770 San Diego, California. 92112 Gentlemen:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION RELATING TO THE STAFF REVIEW OF THE SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 As a result of our review of the Final Safety Analysis Report for the San Onofre Nuclear Generating Station, Units 2 and 3, we find that we need the additional information listed in Enclosure 1.
In addition to the enclosed questions, we would like to advise you of an addi tional open item in our review. Specifically, our approval of the analysis methods used for loss of flow transients at San Onofre depends on our approval of the CENBR code described ib CENPD-177-P. Our review of this topical report has been suspended pending submittal of additional information by Combustion Engineering, Inc. No date has been established for this submittal.
Please contact us if you have any questions about the information requested.
Ongirna Si gned by Robert L. Baer, Chief Light Water Reactors Branch No. 2 DVvi1 Qn of Project Management
Enclosure:
Request for Additional Information ccs w/enclosure,:
See next pages OFFCE.. PM.:.LWR. 2.
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Mr. James H. Drake Vice President Southern California Edison Company 2244 Walnut Grove Avenue P. 0. Box 800 Rosemead, California 91770 Mr. B. W. Gilman Senior Vice President - Operations San Diego Gas and Electric Company 101 Ash Street P. 0. Box 1831 San Diego, California 92112 cc:
Charles R. Kocher, Esq.
James A. Beoletto, Esq.
Southern California Edison Company 2244 Walnut Grove Avenue P. 0. Box 800 Rosemead, California 91770 Chickering and Gregory ATTN: David R. Pigott, Esq.
Counsel for San Diego Gas
& Electric Company and Southern California Edison Company Three Embarcadero Center, 23rd Floor San Francisco, California 94112 Mr. Kenneth E. Carr City Manager City of San Clemente 100 Avenido Presidio San Clemente, California 92672 Alan R. Watts, Esq.
Rourke & Woodruff 1055 North Main Street Suite 1020 Santa Ana, California 92701 Lawrence Q. Garcia, Esq.
California Public Utilities Commission 5066 State Building San Francisco, California 94102 Mr. R. W. DeVane, Jr.
Combustion Engineering, Inc.
1000 Prospect Hill Road Windsor, Connecticut 06095
Mr. James H. Drake Mr. B. W. Gilman cc:
Mr. P. Dragolovich Bechtel Power Corporation P. 0. Box 60860, Terminal Annex Los Angeles, California 90060 Mr.
Mark Medford Southern California Edison Company 2244 Walnut Grove Avenue P. 0. Box 800 Rosemead, California 91770 Henry Peters San Diego Gas & Electric Company Post Office Box 1831 San Diego, California 92112 Ms. Lyn Harris Hicks Advocate for GUARD 3908 Calle Ariana San Clemente, California. 92672 Richard J. Wharton, Esq.
Warton and Pogalies 2667 Camino Del Rio South Suite 106 San Diego, California 92108 Phyllis M. Gallagher, Esq.
1695 West Crescent Avenue Suite 222 Anaheim, California 92701 Mr. A. S. Carstens 2071 Caminito Circulo Norte Mt. La Jolla, California 92037 Resident Inspector/San Onofre Nuclear Power Station c/o U. S. Nuclear Regulatory Commission P. 0. Box 3550 San Onofre, California 92672
MAR 2 0 1980 ENCLOSURE 1 REQUEST FOR ADDITIONAL INFORMATION SAN ONOFRE 2 AND 3 112.0 MECHANICAL ENGINEERING BRANCH 112.35 Identify all piping systems required for safe shutdown of the plant assuming that an SSE has occurred.
112.36 For these systems and the RCS, identify a typical category of com ponent or support within the system that is designed at or close to the allowable stress or strain limit. These categories should be based on commonality of design and qualification.
112.37 For each of these types of components or supports, provide in tabular form the margin to the allowable limit for total stress or strain and the fraction of the total due to seismic input.
112.38 For each of these types of components or supports, provide the estimated (lower bound) overall margin to failure. One approach to this would be to estimate each of the factors that are combined to determine the overall margin to failure. These factors typically include such items as:
- a. the required safety factor on the designated failure mode (ten sion, buckling, etc.)
- b. specific versus actual material properties
- c. assumptions made on load sharing in anchored supports, and
- d. elastic analysis procedures.
A lower bound estimate of the total available margin could be made by multiplying the previously obtained margin to allowable, by the factor determined in this evaluation.
112.39 The following safety-related piping systems and their supports have been selected for further evaluation:
- a. reactor coolant system (including isolation valves and branch lines)
- b. high pressure safety injection system
- c. shut down cooling system
- d. auxiliary feedwater system
- e. diesel generator fuel oil system
- f. selected portions of the main steam system (i.e., power operated atmospheric dump valves and main steam safety valves)
MAR 2 190
-2 For each of these systems, provide the total stress, % seismic input and the margin to allowable at various points in the above systems and their supports.
Confirm that the analyses used represent the as-built-installed configuration (IE Bulletin 79-14).
The NRC staff and consultants (ETEC) will examine in detail the above safety related piping systems and supports according to the "Evaluation of the Implementation of Design Criteria" document (See Enclosure 2).
It is expected that the staff and consultants will select one or more of these systems and request that stress profiles or other similar appropriate aids be developed which will assist in demon strating the margin available to accommodate any change in the design seismic input.
112.40 Provide the details of the evaluation criteria and techniques used to isolate and protect the safe shutdown piping systems identified in Itemll2.*35 above, from failure or malfunction of non-seismic structures, systems and components.
MAR 2OO 121.0 MATERIALS ENGINEERING BRANCH -
MATERIALS INTEGRITY SECTION 121.17 We require that your inspection program for Class 1, 2 and 3 components be in accordance with the revised rules in 10 CFR Part 50, Section 50.55a, paragraph (g).
Accordingly, submit the following information:
(1) A preservice inspection plan which is consistent with the required edition of the ASME Code. This inspection plan should include any exceptions you propose to the Code requirements.
(2) An inservice inspection plan submitted within six months of the anticipated date for commercial operation.
This preservice inspection plan will be required to support the safety evaluation report finding regarding your compliance with preservice and inservice inspection requirements. Our determination of your compliance will be based on:
(1) That edition of Section XI of the ASME Code referenced in your FSAR or later editions of Section XI referenced in the FEDERAL REGISTER that you may elect to apply.
(2) All augmented examinations established by the Commission when added assurance of structural reliability was deemed necessary.
Examples of augmented examination requirements can be found in the NRC.positions on:
(1) high energy fluid systems in Section 3.6 of the Standard Review Plan (SRP), NUREG-75/087; (2) turbine disk integrity in Section 10.2.3 of the SRP; (3) the BWR feedwater inlet nozzle inner radii, NUREG-312, and (4) BWR SS piping NUREG-313.
Your response to this item should define the applicable edition(s) and subsections of Section XI of the ASME Code.
If any of the examination requirements of the particular edition of Section XI you referenced in the FSAR cannot be met, a request for relief must be submitted, including complete technical justification to support your request.
Detailed guidelines for the preparation and content of the inspection programs to be submitted for staff review and for relief requests are attached as Appendix A to Section 121.0 of our review questions.
.*e mA 19MA APPENDIX A GUIDANCE FOR PREPARING PRESERVICE AND INSERVICE INSPECTION PROGRAMS AND RELIEF REQUEST PURSUANT TO 10 CFR 50.55a(g)
A. Description of the Preservice/Inservice Inspection Program This program should cover the requirements set forth in Section 50.55a(g) of 10 CFR Part 50 and the ASME Boiler and Pressure Vessel Code,Section XI, Subsections IWA, IWB, IWC and IWD. The guidance provided in this enclosure is intended to illustrate the type and extent of information that should be provided for NRC review. It also describes the information necessary for "request for relief" of items that cannot be fully inspected to the requirements of Section XI of the ASME Code. By utilizing these guidelines, licensees can significantly reduce the need for requests for additional information from the NRC staff.
B. Contents of the Submittal The information listed below should be included in the submittal:
- 1. For each facility, include the applicable date of the ASME Code and the appropriate addendum date.
- 2. The period and interval for which this program is applicable.
- 3. Provide the proposed codes and addenda to be used for repairs, modifications, additions or alternations to the facility which might be implemented during this inspection period.
- 4. Indicate the examinations that you have exempted under the rules of Section XI of the ASME Code. A reference to the applicable paragraph of the code that grants the exemption is satisfactory.
The inspection requirements for exempt components should be stated (e.g., visual inspection during a pressure test).
- 5. Identify the inspection and pressure testing requirements of the applicable portion of Section XI that are deemed impractical because of the limitation of design, geometry or materials of construction of the components. Provide the information requested in the following section of this appendix for the inspections and pressure tests identified in Item 4 above.
MAR 2 U 1980
-2 C. Reauest for Relief from Certain Inspection and Testino Recuirements Et has been the staff's experience that many requests for relief from testing requirements submitted by licensees-have not been supported by adequate descrtptive and detailed technical Information. This detaftled informatton is necessary to:
(1) document the impracticality of the ASME Code requtrements within the limitations of desi n, geometry and materials of construction of components; and (2) determine whether the use of alternatives will provide an acceptable level of quality and safety.
Relief request submitted with a justification such as "impractical,"
"inaccessible," or any other categorical basis, require additional information to permit the staff to make an evaluation of that relief request. The objective of the guidance provided in this section is to illustrate the extent of the information that is required by the NRC staff to make a proper evaluation and to adequately document the basis for granting the relief in the staff's Safety Evaluation Report. The NRC staff believes subsequent requests for additional information and delays in completing the review can be considerably reduced If this information is provided initially in the licensee's submittal.
For each relief.request submitted, the following information should be included:
- 1. An identification of the component(s) and/or the examination requirement for which relief is requested.
- 2. The number of items associated with the requested relief.
- 3. The ASME Code class.
- 4. An identification of the specific ASME Code requirement that has been determined to be impractical.
- 5. The information to support the determination that the requirEment is impractical; i.e., state and explain the basis for requesting relief.
- 6. An identification of the alternative examinations that are proposed: (a) in lieu of the requirements of Section XI; or (b) to supplement examinations performed partially in compliance with the.requirements of Section XI.
3 MAR 2 U198 0
- 7. A description and justification of any changes expected in the overall level of plant safety by performing the proposed alternative examinations in lieu of the examination required by Sectton XI. If it is not possible to perform alternate examinations, discuss the Impact on the overall level of plant quality and safety.
For inservice inspection, provide the following additional information regarding the inspection frequency:
- 8. State when the request for relief would apply during the inspection period or interval (i.e., whether the request is to defer an examination).
- 9. State when the proposed alternative examinations will be implemented and performed.
- 10. State the time period for which the requested relief is needed.
Technical justification or data must be submitted to support the relief request. Opinions without substantiation that a change will not affect the quality level are unsatisfactory. If the relief is requested for inaccessibility, a detailed description or drawing which depicts the inaccessibility must accompany the request. A relief request is not required for tests prescribed in Section XI that do not apply to your facility. A statement of "N/A (not applicable) or "None" will suffice.
D. Request for Relief for Radiation Considerations Exposures of test personnel to radiation to accomplish the examina tions prescribed-in Section XI of the ASME Code can be an important factor in determining whether, or under what conditions, an examina tion must be performed.
A request for relief must be submitted by the licensee in the manner dez:ibed above for inaccessibility and must be subsequently approved by the NRC staff.
We recognize that some of the radiation considerations will only be known at the time of the test.
However, the licensee generally is aware, from experience at operating facilities, of those areas where relief will be necessary and should submit as a minimum, the following information with the request for relief:
- 1. The total estimated-man-rem exposure involved in the examination.
- 2. The radiation levels at the test area.
MAR 2 V1980
- 4
- 3. Flushing or shielding capabilities which might reduce radiation levels.
- 4. A proposal for alternate inspection techniques.
- 5. A discussion of the considerations involved in remote inspections.
- 7. The results of preservice inspection and any inservice results for the welds for which the relief is being requested.
- 8. A discussion of the consequences if the weld which was not examined, did fail.
361.0 GEOSCIENCES BRANCH 361.63 As part of your response to Question 361.41 you provided a reference entitled "Earthquakes and other Perils San Pedro Region" Edited by Abbott and Elliott.
One of the articles in this reference "Implication of Fault Patterns of the Inner California Continental Borderland Between San Pedro and San Diego" by Greene et al contains a map (page 22) which indicates a possible connection between the Cristianitos fault and the Rose Canyon Fault zone.
A Discussion with two of the authors confirms the possibility of this connection. This postulation is based on limited reflection profiling by the U.S.G.S. In order for us to determine if there is more data available than that which the U.S.G.S.
has analyzed, provide a complete listing and copies of all seismic reflection profiles, within 25 km.
of the Songs.
Also provide all data on the offshore stratigraphy. In particular provide all data on the age of the shallow sediments overlying the postulated offshore extension of the Cristianitos fault.
ENCLOSURE 2 MAR2 219o EVALUATION OF THE IMPLEMENTATION OF DESIGN CRITERIA SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 & 3 DOCKET NO. 50-361/362 I. GENERAL The San Onofre Nuclear Generating Station, Units 2 & 3 are currently designed for a design basis earthquake whose response spectrum has a reference acceleration at the foundation level of 0.67g. Because this plant is located in an area of relatively high seismic activity, the staff plans to review and evaluate the implementation of the design criteria for the Reactor Coolant System (RCS) and other selected Seismic Category I components and their supports which are required for safe shutdown of the plant and continued shutdown heat removal.
The applicant will be requested to present the following information:
- 1. Details of the design analyses for the selected systems, components and their supports.
- 2.
Confirmation that the analyses represent the as-built-installed configuration (I&E Bulletin 79-14).
- 3. Summarize the results of the above analyses in a form which demonstrates the available margins.
- 4. Details of the design criteria with respect to systems interaction between Seismic Category I and non-seismic systems, components and their supports.
S MAR 290 The Energy Technology and Engineering Center (ETEC), under contract to the NRC, will:
- 1. review the plant installed systems (primary and shutdown) and evaluate the analytical models and techniques rsed in the final design and analysis
- 2. review the systems interaction evaluation to determine whether the measures taken to assure the protection of Seismic Category I equipment from the failure of non-seismic equipment are adequate.
The staff Seismic Qualification Review Team will perform an audit of the seismic qualification of items of electrical and mechanical equipment.
Where possible, margins for increased levels of seismic activity will be determined and included in this program.
Paragraphs II, III, IV, and V below provides a more detailed description of this program.
II. PIPING Piping isometric drawings used for the as-built stress analysis will be compared with the piping drawings and the actual system configuration.
Piping modeling techniques will be evaluated to determine (1) the number and adequate location of mass points (2) that the piping geometry is adequately represented and (3) that the supports are correctly modeled.
The applicant will be asked to develop design margin based on ASME Section III criteria, theoretical margin to failure, the seismic portion of total stress and stress profiles for selected systems.
-3 MM AR 1980 III.
COMPONENTS Components will be reviewed as part of the overall system model which includes the piping, dynamically coupled components (i.e., pumps and valves) and supports. The response at a particular component location will determine the required response spectra (RRS) for qualification of that component. This will be compared with the RRS used for component qualification. The structural integrity of valve bodies and pump cases and their supports will be evaluated along with the effects of system deformations on the operability of these components.
Vendor drawings, analysis testing reports and purchase specifications for selected mechanical components will be evaluated to determine the adequacy of the information required for system analysis. The applicant will be requested to determine the design margin by comparison of the design loads and stresses with their allowables.
Interface requirements for the system model will be evaluated and compared with actual design results (e.g., allowable nozzle loads compared with the actual calculated nozzle loads).
IV. SUPPORTS The piping and component support design will be evaluated to assure the structural integrity and operability of the supported component. This evaluation will include the following:
- 1. All Seismic Category I small diameter piping.
- 2. All Seismic Category I tubing required for instrumentation, controls and sampling.
- 3. Yetit "- aucting.
- 4. Cable t
-" aceways.
MAR 2 U1 4
The applicant will be asked to develop design margins based on ASME Section III criteria, theoretical margin to failure, the seismic portion of total stress and stress profiles for selected supports. Support deformation and loads used for the structure interface analysis will be evaluated to determine the adequacy and margin for the support structure interface (i.e., support baseplates and anchor bolting).
V. NON-SEISMIC ITEMS The system interaction analysis between Seismic Category I and non seismic equipment performed by the applicant will be evaluated. This will be accomplished by reviewing the techniques utilized to isolate Seismic Category I equipment from the various modes of failure of non-Seismic equipment. Types and adequacy of isolation and separation techniques will be of prime interest.
Anchors and valving arrangements for seismic to non-seismic transitional piping and protection from fire and explosions from hazardous fluid lines (i.e., hydrogen) will also be evaluated.