ML13305A658
| ML13305A658 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 08/01/1984 |
| From: | Knighton G Office of Nuclear Reactor Regulation |
| To: | Baskin K, Holcombe J San Diego Gas & Electric Co, Southern California Edison Co |
| References | |
| NUDOCS 8408090424 | |
| Download: ML13305A658 (5) | |
Text
AUG1 19t4 Docket Nos.:
50-361 and 50-362 Mr. Kenneth P. Baskin Mr. James C. Holcombe Vice President Vice President - Power Supply Southern California Edison Company San Diego Gas & Electric Company 2244 Walnut Grove Avenue 101 Ash Street Post Office Box 800 Post Office Box 1831 Rosemead, California 91770 San Diego, California 92112 Gentlemen:
Subject:
Request for Additional Information Regarding Procedures Generation Package (PGP)
We are currently reviewing the PGP for San Onofre Nuclear Generation Station (SONGS) 2 and 3. To continue our review of the Plant-Specific Technical Guidelines (PSTG) portion of the PGP, we need the additional information described in the enclosure. Please provide a response to the enclosed request for additional information as soon as practicable. This request supersedes our request of July.13, 1984 on the same subject.
If you have any questions regarding this request, please contact us.
Sincerely, George W. Knighton, Chief" Licensing Branch No. 3 Division of Licensing
Enclosure:
As stated cc:
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.Docket File 50-361/362 JLee JClifford NRC PDR HRood BClayton Local PDR LChandler, OELD LPhillips PRC System ACRS (16)
THuang NSIC EJordan JMazetis LB#3 Reading NGrace DL:LB#3~
D LR 7N /84 1/1 /84 8406090424 640601 PDR ADOCK 05000361 P
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San Onofre Mr. Kenneth P. Baskin Vice President Southern California Edison Company 2244 Walnut Grove Avenue P. 0. Box 800 Rosemead, California 91770 Mr. James C. Holcombe Vice President - Power Supply San Diego Gas & Electric Company 101 Ash Street Post Office Box 1831 San Diego, California 92112 Charles R. Kocher, Esq.
Mr. Mark Medford James A. Beoletto, Esq.
Southern California Edison Company Southern California Edison Company 2244 Walnut Grove Avenue 2244 Walnut Grove Avenue P. 0. Box 800 P. 0. Box 800 Rosemead, California 91770 Rosemead, California 91770 Dr. L. Bernath Manager, Nuclear Department Orrick, Herrington & Sutcliffe San Diego Gas & Electric Company ATTN:
David R. Pigott, Esq.
P. 0. Box 1831 600 Montgomery Street San Diego, California 92112 San Francisco, California 94111 Richard J. Wharton, Esq.
University of San.Diego School of Alan R. Watts, Esq.
Law Rourke & Woodruff Environmental Law Clinic Suite 1020 San Diego, California 92110 1055 North Main Street Santa Ana, California, 92701 Charles E. McClung, Jr., Esq.
Attorney at Law Mr. V. C. Hall 24012 Calle de la Plaza/Suite 330 Combustion Engineering, Inc.
Laguna Hills, California 92653 1000 Prospect Hill Road Windsor, Connecticut 06095 Region Administrator-Region V/NRC 1450 Maria Lan/Suite 210 Mr. S. McClusky Walnut Creek, California 92672 Bechtel Power Corporation P. 0. Box 60860, Terminal Annex Los Angeles, California 90060 Resident Inspector, San Onofre NPS c/o U. S. NRC Mr. C. B. Brinkman Post Office Box 4329 Combustion Engineering, Inc.
San Clemente, California 92672 7910 Woodmont Avenue Bethesda, Maryland 20814 Mr. Dennis F. Kirsh U.S. Nuclear Regulatory Commission - Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596
REQUEST FOR ADDITIONAL INFORMATION SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 PROCEDURES GENERATION PACKAGE The staff is currently reviewing the San Onofre 2 and 3 Procedures Generation Package (PGP) submitted by a letter dated April 6, 1984, from M. 0. Medford to G. W. Knighton. We have determined that additional information is needed for the staff to conduct a detailed review of the plant-specific technical guidelines (PSTG) portion of the PGP. The staff is currently conducting a detailed review of the three remaining portions of the PGP; namely, the plant-specific writer's guide, the validation/verification program description, and the training program description. To allow us to continue our review of the PSTG, the following information should be provided as a revision to the San Onofre 2 and 3 PGP.
- 1. The process described on pages A-9 and A-10 of the PGP includes: (1) the additional of plant-specific details to the guidelines steps, (2.)
the identification of additional plant-specific steps, (3) the deletion or modification of generic steps that cannot be performed at SONGS 2 and 3, and (4) the determination of safety significant deviations or additions and their justification. These are items 3, 4, 5, and 8 respectively of Section 3.2 of the PGP. The safety significant deviations or additions identified in these categories, along with appropriate analytical or other technical justification, should be submitted to the NRC for review and approval. This will enable the staff to complete its review of the Instructions (EOIs), as required by Supplement 1 to NUREG-0737, "Requirements for Emergency Response Capability."
- 2. The PGP should be expanded to provide a description of the process that has been, or will be, used to identify the information and control requirements of the operators, and, in addition, a description of the analysis or process used to ensure the availability and adequacy of the instrumentation and controls to meet the identified needs. This is necessary to complete the function and task analysis required by Supplement 1 to NUREG-0737.
These items must be submitted to the NRC and reviewed prior to approval of the PGP. As stated in Supplement 1 to NUREG-0737, the review of the PGP is a post-implementation review. It is, therefore, not necessary to delay implementation of the upgraded EOI's while the information requested in the above items are submitted and reviewed. However, the four items discussed below should be incorporated into the upgraded San Onofre 2 and 3 EOI's prior to their implementation.
-2 The NRC staff has completed its review of the reactor vessel level monitoring system (RVLMS) as it applies to San Onofre Units 2 and 3 for use as a part of the ICC instrumentation. As agreed to in the June 29, 1984 meeting, SCE has agreed to defer incorporation of the CEN-152, Revision 2 guidance regarding reactor coolant pump Trip 2/Leave 2 in its Emergency Operating Instrumentations (EOIs) until the NRC staff completes its review of the remainder of CEN-152, Revision 2.
Based on its review, the NRC staff has concluded that use of the ICC instrument ation specified in CEN-152, Revision 2 at San Onofre Units 2 and 3, is acceptable provided that the following items are incorporated in the EOIs based on CEN-152, Revision 1 using the ICC instrumentation specified in CEN-152, Revision 2:
- 1. At numerous points throughout the guidelines an acceptable criterion is indicated as RCS 20'F subcooled. Initially, the subcooling margin was measured using the reactor vessel pressure and the hot leg coolant temperature, usually with an RTD (TH). It is presumed that the indicated acceptance margin refers to the TH measurement of SMM. For near normal conditions or slowly proceeding transients, particularly with main coolant pumps running, this measurement is adequate. A statement to this effect appears on page 4-12 of the guidelines.
The procedures encompass a wide range of emergency conditions which include pumps not running, and more rapid transients. Under such conditions, there is typically a significantly larger temperature difference between the hot leg (TH) and core exit or upper head. Since these hot areas are where voiding is likely to occur first and the subcooling margin will be the least, it would seem advisable to include in the procedures appropriate reference to SMM as calculated by core-exit thermocouples (CET) and upper head (UH) thermocouples. The guidelines include only 2 or 3 instances in the Functional Recovery Guidelines where CET calculated SMM is to be used.
Approved EOP guidelines pertaining to final ICC instrumentation rely on a CET calculated SMM, and CE plants using heated junction thermocouples (HJTC) also have the capability to calculate upper head (UH) SMM. It is recommended that the most sensitive indication of low SMM and potential voiding be used where appropriate in the guidelines; that is, where significant differences between UH, CET, and TH temperatures are expected.
-3
- 2. The guidelines refer only to CET temperatures and do noi suggest which or how many of the CETs should be used for acceptance of condition of procedural guidance. This may be a plant specific concern, but general guidance may also be in order.
- 3. The HJTC systems have generally been accepted by the NRC for Reactor Vessel Level Measuring Systems (RVLMS) on a generic basis. It would seem appropriate to include generic guidance on interpreting the level information display, particularly where dynamic conditions may cause difficulty of interpretation. "Important information concerning reactor vessel liquid inventory trending..." (see page 6-15, Item 14; page 9-11, Item 8; and others) requires a considerable guidance for interpretation of indications, which is not included in the EPGs.
The guidance should be applicable to both split and single HJTC probe users.
- 4. A few phrases are used repeatedly in the EPGs which require considerable interpretation of indications for which no specific guidance is given:
"... voiding is present..." or "...no voiding is present..." No guidance is given for this interpretation, including no advice or selection of the most sensitive indicator (see Item 1 above).
"...core is covered..." While plant specific, this guidance is a bit vague in relation to instrument indications and especially to allowing margin for approach to core uncovery.
follow inventory trend...
(see Item 3 above).
"... indication of unacceptable RCS voiding... " No definition of unacceptable" voiding is suggested.
These phrases need to be consistently defined.
NRC staff review of generic technical guidelines (CEN-152, Revision 2, including RVLMS) is ongoing and may require further changes to the San Onofre Units 2 and 3 EOIs. SCE must revise the San Onofre Unit 2 and 3 E0Is to address any additional changes resulting from the staff reviewed of CEN-152, Revision 2 prior to startup following the next refueling outage that occurs six months or more after approval of the CEN-152, Revision 2 guidelines.