ML15159A188
| ML15159A188 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/04/2015 |
| From: | Brabec R Southern California Edison Co |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML15159A188 (23) | |
Text
SOUTHERN CALIFORNIA Richard C. Brabec EDISON Principal Manager, Nuclear Regulatory Affairs EO and Emergency Planning An EDISON INTERNATIONAL Company June 4, 2015 10 CFR 50.59 10 CFR 50.71 10 CFR 72.48 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001
Subject:
Docket Nos. 50-206, 50-361, 50-362, and 72-41 Facility Change Report, Summary Report of Commitment Changes, and Cycle Specific Technical Specification Bases Page Updates San Onofre Nuclear Generating Station (SONGS) Units 1, 2 and 3, and the Independent Spent Fuel Storage Installation (ISFSI)
Dear Sir or Madam:
The attached enclosure contains the Facility Change Report as required by 10 CFR 50.59(d)(2) for SONGS Units 1, 2, and 3, and by 10 CFR 72.48(d)(2) for the ISFSI. The enclosed report provides a brief description and summary of 10 CFR 50.59 evaluations performed for any changes, tests, and experiments during the reporting period from February 1, 2013 through April 1, 2015. The report scope includes evaluations for changes implemented and currently in process. There were no 10 CFR 50.59 evaluations performed for SONGS Unit 1 during this time period. There were no 10 CFR 72.48 evaluations performed for the ISFSI during this time period. Complete facility change documentation for the SONGS Units 2 and 3 10 CFR 50.59 evaluations is available onsite.
This letter would also provide a summary of comment changes following the guidance of Nuclear Energy Institute (NEI) 99-04, "Guidelines for Managing NRC Commitment Changes,"
Revision 0. However, for the most recent reporting period, from March 1, 2014 through April 1, 2015, no commitments were identified as reportable under the NEI guidelines.
As required under SONGS Units 2 and 3 Technical Specification (TS) 5.4.4, changes to the SONGS Units 2 and 3 TS Bases made without prior Nuclear Regulatory Commission (NRC) approval are provided to the NRC on a frequency consistent with 10 CFR 50.71(e). There were no changes to the SONGS Units 2 and 3 TS Bases for the period between February 1, 2013 through April 1, 2015 for SONGS Units 2 and 3.
This letter, or the attached enclosure, does not contain any new commitments.
P.O. Box 128 San Clemente, CA 92672 (949) 368-7418 PAX 87418 Fax: (949) 368-7575 John.Brabec@sce.com
Document Control Desk June 4, 2015 If you have any questions or would like any additional information, please contact Mr. Mark Morgan, at (949) 378-6745.
incerely,
Enclosure:
As Stated cc: W. C. Allen, NRC Project Manager, SONGS ISFSI M. L. Dapas, Regional Administrator, NRC Region IV M.G. Vaaler, NRC Project Manager SONGS Unit 1 T. J. Wengert, NRC Project Manager, San Onofre Units 2 and 3
SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
ENCLOSURE SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 and 3 FACILITY CHANGE REPORT (FCR) 10 CFR 50.59 EVALUATION SUMMARIES FOR THE PERIOD FROM FEBRUARY 1, 2013 THROUGH April 1, 2015 I
SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Index of 10 CFR 50.59 Evaluation Summaries Title Page Unit 2 Cycle 17 Reload ECP Affected Section Change .......................................................... 4 Proposed Revision to Procedure S023-13-4, Abnormal Operating Instruction ........................ 5 Permanently Remove From Service the Full Flow Condensate Polishing System .................. 6 Permanently Remove From Service the Turbine Plant Chemical Addition System ................. 6 Turbine and Auxiliary Systems (TBNS), Generator Systems (GENR), Turbine Control System (TBNS) Permanent Removal From Service ............................................................................ 7 Modification to Operations Procedure S023-9-1.1, Revision 10, "Outage Operation Of Feedwater Heaters" ........................................................................... 8 Main Steam System Permaneht Removal From Service ......................................................... 8 Blowdown Processing System Permanent Removal From Service ......................................... 8 Circulating Water System Sodium Hypochlorite sub-system Permanent Removal F ro m S e rv ice ......................................... .................................................................................... 9 Steam Bypass Control System (SBCS) Permanent Removal From Service .......................... 9 Reactor Coolant Pumps and 6.9 KV System Permanent Removal From Service .................. 10 Reactor Coolant System Permanent Removal From Service ................................................ 10 Containment HVAC Recirculation Cleanup System Permanent Removal From Service ..... 10 Control Element Drive Mechanism (CEDM) System and the Anticipated Transient Without Scram (ATWS) System Permanent Removal From Service .................................................. 11 Hydrogen Gas System Permanent Removal From Service .................................................. 11 Hydrogen Monitoring System Permanent Removal From Service ......................................... 11 Steam Generators Permanent Removal From Service ........................................................ 12 Permanent Removal From Service ECCS, SDS, HPSI CSS, CVCS .................................... 12 Revise UFSAR Section 2.4.12 and UFSAR Section 11.2.3.2 to limit the maximum liquid radwaste system discharge to less than 95 gpm ............................ 13 Vibration and Loose Parts Monitoring System (VLPMS) Permanent Removal From Service .... 13 Permanently securing Normal Chilled Water to Normal Cooling Unit E430 for both Units ......... 14 2
SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Index of 10 CFR 50.59 Evaluation Summaries Title Page Allow use of Emergency Diesel Generator (EDG) Cross-tie to Support Plant Operations ......... 15 Reclassify all Safety Related Electrical SSCs to Non-safety Related .................................... 16 Auxiliary Feedwater System Permanent Removal From Service ........................................... 17 Coolant Radwaste System (CRS) Permanent Removal From Service .................................. 17 Delete Licensee Controlled Specifications 3.3.112 Fuel Handling Isolation Signal and 3.7.118 Fuel Handling Building Post-Accident Cleanup Filter System ............................ 18 Revise Licensee Controlled Specification (LCS) 3.7.106 Spent Fuel Pool Operation ............ 19 Gaseous Radwaste System Permanent Removal From Service ........................................... 20 Shutdown Cooling System (SDC) Permanent Removal From Service .................................. 21 3
SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Unit 2 Cycle 17 Core Reload ECP 800698429-0230, Affected Section Change D0069586
==
Description:==
The proposed activity implements the Unit 2 Cycle 17 Core Reload ECP and the associated Affected Section Change. The most significant changes for Unit 2 Cycle 17 core reload were:
(1) Core design analysis as supported by CASMO-4 / SIMULATE-3 codes, (2) Changes in core fuel loading pattern, (3) Safety analysis evaluation of core fuel pattern changes, (4)
Westinghouse Lead Fuel Assemblies (LFAs), (5) AREVA Lead Fuel Assemblies (LFAs), (6)
Tcold Restoration to 550F, (7) Reactor Vessel Head Replacement, (8) Extended Reduced Power Operation at or above 67.5% Power Level.
Evaluation Summary:
With the permanent defueling of Unit 2, the prepared evaluation was not implemented.
For those UFSAR Chapter 15 events that included a pre-existing iodine spike, the proposed change increased the assumed magnitude of the pre-accident iodine spike. The increase in the pre-accident iodine spike in the Steam Generator Tube Rupture (SGTR) and post-trip Steam Line Break (SLB) dose analyses increased the iodine activity present in the post-accident steam released to the environment via the Main Steam Safety Valves (MSSVs) and Atmospheric Dump Valves (ADVs). The increased iodine activity resulted in higher doses at the offsite Exclusion Area Boundary (EAB) and outer boundary of the Low Population Zone (LPZ), and in the Control Room (CR). The increased iodine spike doses for the SGTR event were not more than minimal.
4
SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Proposed Revision to Procedure S023-13-4, Abnormal Operating Instruction 202026713-024
==
Description:==
The SONGS switchyard is the sole interconnection between the SCE and SDG&E transmission grids. As described in UFSAR Section 8.2.1.3.3, the switchyard system separation scheme provides a means of selecting either the SCE or SDG&E system to supply the on-site power systems in the event of a grid transient. With both SONGS units off line, the Grid Control Center (GCC) / California Independent System Operator (CAISO) was concerned a malfunction of the system separation scheme could cause SDG&E customers to lose power. The revised procedure allows disabling the system separation scheme (relay house switch 8-OL positioned to 'Off) at the discretion of the grid operator. The 50.59 evaluation was completed prior to the permanent shutdown of SONGS.
Evaluation Summary:
The proposed change to defeat the operation of the system separation scheme is acceptable, based on the compliance with industry standards, and with applicable mode restrictions.
The frequency of occurrence of accidents and likelihood of malfunctions are not increased for Unit 2 because the incoming transmission lines, switchyard busses, and pathways to the onsite Class 1 E busses can be isolated by operating switches in the SONGS Control Room for the individual breakers on: the SCE incoming lines; the bus ties (which isolate the SDG&E incoming lines from the Unit 2 transformer positions); and the Unit 2 transformer positions. Unit 2 therefore meets the Standard Review Plan 8.2 Paragraph 1II.d.1 criteria (restore power from the redundant source) independent of the status of the system separation scheme. As such, for Unit 2, the Technical Specification operability of the two required offsite AC sources is not affected by the position of the system separation selector switch (8-OL) in the switchyard relay house. Manual system separation for Unit 2 is unaffected. Analysis demonstrates that with one or both SONGS units on line, or offline, the overload condition that actuates automatic system separation will not be reached for GDC 17 grid contingency conditions (loss of largest unit, load or line), and the frequency category for Loss of Offsite Power (LOOP) is not affected by the presence or absence of the automatic separation feature.
For Unit 3 only, the incoming SCE transmission lines, switchyard busses, and pathways to the onsite Class 1 E busses can be isolated by operating switches in the SONGS Control Room for the individual breakers. Isolation of the incoming SDG&E lines can be performed from the SONGS control room only by actuating the system separation scheme. Therefore, Unit 3 requires the system separation scheme to comply with the Standard Review Plan 8.2 Paragraph Ill.d.1 criteria. As such, for Unit 3, the Technical Specification operability of the two required offsite AC sources has been affected by the position of the system separation selector switch in the switchyard relay house, and changing the switch position (or a modification to provide control of the individual breakers on the incoming SDG&E transmission lines from the SONGS Control Room), is a restraint to Unit 3 entering mode 4.
5
SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Permanently Remove From Service the Full Flow Condensate Polishing System 202510626-03
==
Description:==
The Full Flow Condensate Polishing system has been identified as a system that should be abandoned and will be permanently removed from service. On June 12, 2013, SCE formally notified the NRC that it has permanently ceased operation of Units 2 and 3 with the submittal of a Certification of Permanent Cessation of Operations. Therefore, the Full Flow Condensate System is no longer required to remain functional.
Evaluation Summary:
The Full Flow Condensate System has no safety function and will be permanently removed from service. As described in the 50.59 evaluation responses, the Full Flow Condensate System is not credited for a loss of spent fuel cooling. Any failure modes and effects described in the UFSAR for the Feedwater and Condensate Systems are only analyzed for conditions other than the permanently defueled condition.
Permanently Remove From Service the Turbine Plant Chemical Addition System 202510680-03
==
Description:==
On June 12, 2013, SCE formally notified the NRC that it has permanently ceased operation of Units 2 and 3 with the submittal of a Certification of Permanent Cessation of Operations.
Therefore, the Turbine Plant Chemical Addition System (TPCA) system is no longer required to remain functional and has no safety function. TPCA has been identified as a system that should be abandoned and will be removed from service. No chemically adjusted water will be pumped through either the main feed water or the auxiliary feed water systems and no chemical treatment is required.
Evaluation Summary:
The TPCA System will be permanently removed from service for the defueled condition. The Full Flow Condensate System is not credited for a loss of spent fuel cooling. Any failure modes and effects described in the UFSAR for the Feedwater and Condensate Systems are only analyzed for conditions other than defueled.
6
SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Turbine and Auxiliary Systems (TBNS), Generator Systems (GENR), and Turbine Control Systems (TBNS) Permanent Removal From Service 202510704-07
==
Description:==
The Turbine and Auxiliary Systems, Generator Systems, and Turbine Control System (TBNS, GENR, and TBNC) have been evaluated and categorized as being acceptable to be permanently removed from service (i.e. abandoned) in support of the planned decommissioning of San Onofre. The Turbine and Auxiliary System (TBNS) is comprised of the following Systems:
- 1) Main Turbine
- 3) Main Lube Oil System
- 4) Seal Oil System
- 5) Moisture Separator Reheaters (MSRs) System (i.e. including drain tanks)
- 6) LP Spray System
- 7) Stator water System
- 8) Hydrogen Dryer system
- 9) Portions of the Hydrogen supply System
- 10) Turbine Gland Sealing System The Generator Systems (GENR) includes:
- 1) Main generator
- 2) Main Generator Excitation and Voltage Control System
- 3) Generator Trips
- 4) Isophase Bus and Cooling System (not explicitly mentioned in the UFSAR but is included in this evaluation)
The Turbine Control System (TBNC) includes:
- 1) Digital Electrohydraulic Governor (DEHG) System
- 3) Instrumentation Applications (Turbine Supervisory, etc.)
Evaluation Summary:
The Turbine and Auxiliary Systems, Generator Systems, and Turbine Control Systems (TBNS, GENR, and TBNC) will be permanently removed from service for the defueled condition. As described in the evaluation responses, the TBNS and GENR systems are not credited for a loss of spent fuel cooling. Any failure modes and effects described in the UFSAR for the Turbine and Auxiliary Systems are only analyzed for conditions other than defueled.
7
SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Modification to Operations Procedure S023-9-1.1, Revision 10, "Outage Operation Of Feedwater Heaters" 202495694-09
==
Description:==
Procedure Modification Permit (PMP) # 1 to S023-9-1.1, Revision 10, changes portions of , "Draining of Feedwater Heaters and Drain Tanks," to allow for permanent removal of these components from service in preparation for the permanent removal from service of the Condensate and Feedwater Systems.
Evaluation Summary:
The feedwater heaters and drain tanks will be permanently removed from service for the defueled condition. The Feedwater and Condensate Systems are not required to support any accidents credible in the defueled mode. Any failure modes and effects described in the UFSAR for the Feedwater and Condensate Systems are only analyzed for conditions other than defueled.
Main Steam System Permanent Removal From Service 202510749-03
==
Description:==
The Main Steam System has been identified as a system that should be abandoned and will be removed from service. This includes the mechanical portion of the Turbine Bypass System (Steam Bypass System mechanical portion). For the purpose of this evaluation the Main Steam System and Turbine Bypass System will be referred to as the Main Steam System.
Evaluation Summary:
The Main Steam System will be permanently removed from service for the defueled condition.
The Main Steam System is not required to support any accidents credible in the defueled mode.
Any failure modes and effects described in the UFSAR for the Main Steam System are only analyzed for conditions other than defueled.
Blowdown Processing System Permanent Removal From Service 202510763-03
==
Description:==
On June 12, 2013, SCE formally notified the NRC that it has permanently ceased operation of Units 2 and 3 with the submittal of a Certification of Permanent Cessation of Operations.
Therefore, the Blowdown Processing System (BPS) is no longer required to remain functional.
Evaluation Summary:
The Blowdown Processing System will be permanently removed from service for the defueled condition. The Blowdown Processing System has no safety function and is not required to support any accidents credible in the defueled mode. Any failure modes and effects described in the UFSAR for the Blowdown Processing System are only analyzed for conditions other than defueled.
8
SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Circulating Water System Sodium Hypochlorite sub-system Permanent Removal From Service 202517405-03
==
Description:==
The Circulating Water System Sodium Hypochlorite sub-system has been identified as a plant system that may be removed from service and isolated from the circulating water systems. The hypochlorite equipment may be aligned, drained, and treated by operation procedures as abandoned.
Evaluation Summary:
The Circulating Water Sodium Hypochlorite sub-systems and the common hypochlorite storage tank will be permanently removed from service for the defueled condition. The Circulating Water Sodium Hypochlorite sub-systems and the common hypochlorite storage tank do not have safety functions and are not required to support any accidents in the defueled mode.
The failure modes and effects described in the UFSAR are not applicable to the Circulating Water Sodium Hypochlorite sub-system. Turbine building flooding discussed in UFSAR Table 3.4-2, "Effects of flooding from Component Failures (Sheet 8 of 18)," remains applicable but is not adversely affected by taking the Sodium Hypochlorite sub-system of service.
Steam Bypass Control System (SBCS) Permanent Removal From Service 801095572-0030
==
Description:==
Design Change NECP 801095572 modifies the UFSAR description of the Steam Bypass Control System (SBCS) to document the elimination of required system functionality as currently described in the UFSAR. The functionality of the SBCS is not required in the defueled condition following permanent shutdown of the two units.
Evaluation Summary:
The SBCS will be permanently removed from service for the defueled condition. As described in the evaluation responses, the SBCS has no function to support any accidents credible in the defueled mode. Any failure modes and effects described in the UFSAR for the SBCS are only analyzed for conditions other than defueled.
9
SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Reactor Coolant Pumps and 6.9 KV System Permanent Removal From Service 202523065-03
==
Description:==
The Reactor Coolant Pumps and the associated 6.9kV power supply system have been identified as systems that should be abandoned and will be removed from service. On June 12, 2013, SCE formally notified the NRC that it has permanently ceased operation of Units 2 and 3 with the submittal of a Certification of Permanent Cessation of Operations. Therefore, the Reactor Coolant Pumps are no longer required to remain functional.
Evaluation Summary:
The Reactor Coolant Pumps and the associated 6.9 kV power supply system will be permanently removed from service for the defueled condition. The Reactor Coolant Pumps and the 6.9 kv power supply system are not credited for any accident credible in the defueled mode.
Any failure modes and effects described in the UFSAR are only analyzed for conditions other than defueled.
Reactor Coolant System Permanent Removal From Service 202525345-03
==
Description:==
On June 12, 2013, SCE formally notified the NRC that it has permanently ceased operation of Units 2 and 3 with the submittal of a Certification of Permanent Cessation of Operations. All fuel has been removed from the reactor vessel, therefore the Reactor Coolant System is no longer required to remain functional.
Evaluation Summary:
The Reactor Coolant System will be permanently removed from service for the defueled condition. The Reactor Coolant System is not credited for any accident credible in the defueled mode. Any failure modes and effects described in the UFSAR are only analyzed for conditions other than defueled.
Containment HVAC Recirculation Cleanup System Permanent Removal From Service 202526618-03
==
Description:==
On June 12, 2013, SCE formally notified the NRC that it has permanently ceased operation of Units 2 and 3 with the submittal of a Certification of Permanent Cessation of Operations.
Therefore, the Containment Recirculation Cleanup Units are no longer required to remain functional.
Evaluation Summary:
The Containment Recirculation Cleanup Units and charcoal filters will be permanently removed from service for the defueled condition. The Containment Recirculation Cleanup Units and charcoal filters are not required to support any accidents credible in the defueled mode.
10
SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Control Element Drive Mechanism (CEDM) System and the Anticipated Transient Without Scram (ATWS) System Permanent Removal From Service 801097341-0030
==
Description:==
Design Change NECP 801097341 modifies the UFSAR descriptions of the Control Element Drive Mechanism (CEDM) system, and the Anticipated Transient Without Scram (ATWS) system to document the elimination of required system functionality as currently described in the UFSAR.
Evaluation Summary:
The CEDM and ATWS systems will be permanently removed from service for the defueled condition. The CEDM and ATWS systems are not required to support any accidents credible in the defueled mode. Any failure modes and effects described in the UFSAR for the CEDM and ATWS systems are only analyzed for conditions other than defueled.
Hydrogen Gas System Permanent Removal From Service 202526610-03
==
Description:==
On June 12, 2013, SCE formally notified the NRC that it has permanently ceased operation of Units 2 and 3 with the submittal of a Certification of Permanent Cessation of Operations.
Therefore, the Hydrogen Gas System is no longer required to remain functional.
Evaluation Summary:
The Hydrogen Gas System will be permanently removed from service for the defueled condition. The Hydrogen Gas System has no safety function and is not credited for a loss of spent fuel pool cooling accident. Any failure modes and effects described in the UFSAR for this system is only analyzed for conditions other than defueled.
Hydrogen Monitoring System Permanent Removal From Service 801097185-0050
.Description:
Design Change NECP 801097185 modifies the UFSAR descriptions of the Hydrogen Monitoring Systems in the two units to document the elimination of required system functionality as currently described in the UFSAR. The Hydrogen Monitoring System has no function in the defueled condition following permanent shutdown of the two units.
Evaluation Summary:
The Hydrogen Monitoring System will be permanently removed from service for the defueled condition. The Hydrogen Monitoring System is not required to support any accidents credible in the defueled mode. Any failure modes and effects described in the UFSAR for the Hydrogen Monitoring System are only analyzed for conditions other than defueled.
I1
SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Steam Generators Permanent Removal From Service 202526652-07
==
Description:==
On June 12, 2013, SCE formally notified the NRC that it has permanently ceased operation of Units 2 and 3 with the submittal of a Certification of Permanent Cessation of Operations.
Therefore, the Steam Generators (S2.STGS.$21301 ME088, $2.STGS.$21301 ME089,
$3.STGS.$31301 ME088, $3.STGS.$31301 ME089) are no longer required to remain functional.
Evaluation Summary:
The Steam Generators will be permanently removed from service for the defueled condition.
The Steam Generators are not credited for any accidents credible in the defueled mode. Any failure modes and effects described in the UFSAR are only analyzed for conditions other than defueled.
Permanent Removal From Service ECCS, SDS, CSS, HPSI, CVCS 202525344-03
==
Description:==
On June 12, 2013, SCE formally notified the NRC that it has permanently ceased operation of Units 2 and 3 with the submittal of a Certification of Permanent Cessation of Operations.
Therefore, the Emergency Core Cooling System (ECCS), Shutdown Cooling System (SDS),
Containment Spray System (CSS), High Pressure Safety Injection (HPSI) System, and Chemical and Volume Control System (CVCS) are no longer required to remain functional.
Evaluation Summary:
The Emergency Core Cooling System (ECCS), Shutdown Cooling System (SDS), Containment Spray System (CSS), High Pressure Safety Injection (HPSI) System, and the Chemical and Volume Control System (CVCS) will be permanently removed from service for the defueled condition. These systems have no function in the defueled mode and not credited for any accident credible in the defueled mode. Any failure modes and effects described in the UFSAR are only analyzed for conditions other than defueled.
12
SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Revise UFSAR Section 2.4.12 and UFSAR Section 11.2.3.2 to limit the maximum liquid radwaste system discharge to less than 95 gpm 801102607-060
==
Description:==
The proposed activity will update UFSAR Section 2.4.12 and UFSAR Section 11.2.3.2 by reducing the maximum liquid radwaste effluent discharge to less than 95 gpm. In addition, the proposed activity will update UFSAR Section 2.4.12 and UFSAR Section 11.2.3.2 by updating the minimum plant outfall flowrate to 28,000 gpm. These changes are consistent with dilution using two salt water cooling pumps at a minimum flow of 14,000 gpm. The previous analysis was based on using circulating water pumps with higher capacity flowrates (i.e. with a dilution factor order of magnitudes higher). The UFSAR change supports the draft revision of ODCM using saltwater cooling pumps for dilution of liquid radwaste effluent discharge.
Evaluation Summary:
Automatic isolation of the radwaste effluent occurs upstream of the circulating water outfall header as described in UFSAR Section 11.5.2.1.4.3, and this function is unchanged. Dilution flowrate is not an initiator of any accident previously evaluated. The UFSAR does not credit automatic isolation of radwaste discharge line upon loss of dilution flow, so there is no increase in the probability or consequences of a previously evaluated malfunction. Following implementation of this change, any release will remain within 10 CFR 20 limits, and follow the recommendations of Regulatory Guide 1.21.
Vibration and Loose Parts Monitoring System (VLPMS) Permanent Removal From Service 202521892-06
==
Description:==
On June 12, 2013, SCE formally notified the NRC that it has permanently ceased operation of Units 2 and 3 with the submittal of a Certification of Permanent Cessation of Operations.
Therefore the Vibration and Loose Parts Monitoring System (VLPMS) is no longer required to remain functional.
Evaluation Summary:
The VLPMS will be permanently removed from service for the defueled condition. The VLPMS is not required to support any accidents credible in the defueled mode. Any failure modes and effects described in the UFSAR for the VLPMS are only analyzed for conditions other than defueled.
13
SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Permanently securing Normal Chilled Water to Normal Cooling Unit E430 for both Units 202582143-03
==
Description:==
The proposed activity will permanently secure the Normal Chilled Water supply to Normal Cooling Unit E430 for both Units. The air handling portion of the Normal Cooling Unit E430 will remain in service to provide outside air ventilation and cooling without the normal chilled water supplied to the cooling coils.
In addition, the proposed activity will maintain the normally standby Train A and/or Train B Emergency Cooling Units in service to meet temperature design requirements during Normal and Emergency conditions (previously operated for emergency conditions only).
Evaluation Summary:
The proposed activity of securing the Normal Chilled Water supply to Normal Cooling Unit (E430) and placing E430 in service for ventilation and outside air cooling, without chilled water supplied to the cooling coils, is acceptable to implement. The Normal Chilled Water supply and the Normal Cooling Unit are both non-safety related and not important to safety. As such, the UFSAR does not credit these systems to be available for accident mitigation or safe shutdown.
SCE evaluated the loss of normal HVAC and determined the steady state temperature remained below the required limit.
The proposed activity of placing the normally standby Emergency Cooling Units (E255/257) in service for long-term operation is acceptable to implement. As credited in the UFSAR, emergency cooling can be operating without isolation of normal cooling. Furthermore, having the system in service alleviates the failure modes associated with a standby system.
Continuous operation creates the possibility of a previously unanalyzed rotating component missile failure, however analysis confirmed the fan blade would be contained by the casing, therefore no other SSCs could be affected and thus the malfunction does not have a different result than previously analyzed.
14
SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Allow use of Emergency Diesel Generator (EDG) cross-tie to support plant operations 202643370-01
==
Description:==
On June 12, 2013, SCE formally notified the NRC that it has permanently ceased operation of Units 2 and 3 with the submittal of a Certification of Permanent Cessation of Operations. With both units in a permanently defueled condition, some of the requirements applicable to the operating units can be relaxed. This change will allow an EDG from one unit to be credited for cross-tie to the other unit outside of, and independent of, the 50.54(x) process when in the permanently defueled condition and not moving fuel.
Evaluation Summary:
The primary benefit of this change is in the implementation of LCS 3.7.106, for SFP cooling.
LCS 3.7.106 requires that one EDG be functional to support SFP cooling in the event of a loss of off-site power. This change will allow a single EDG to support both units. Associated Task SPT-2 concluded a single EDG can support the required loads of both units in the permanently defueled condition. The change is beneficial, partly because it is more reliable for a diesel engine to operate at loads nearer full capacity than at lower loads. Having an EDG operate at low loads, such as the loads of a single defueled unit, decreases its reliability.
The capability and physical hardware exists to cross-connect the EDG from one unit to the same train 4.16 kV Class 1E bus of the other unit. However, the UFSAR currently prohibits cross-tying the EDGs outside of the 50.54(x) process. With this change, the breakers for the cross-tie would remain normally open, as there is sufficient time to procedurally close the breakers and energize the opposite unit buses in the event of a loss of offsite power.
In general, the UFSAR prohibited cross-tying the EDGs from one unit to the other except in emergency situations, to prevent transients on one unit, or a single failure, from affecting both units. However, with both units in a permanently defueled condition, these concerns are no longer valid. Analysis has shown that one EDG can readily carry the loads of the two defueled units, primarily the loads necessary to support SFP cooling. The EDGs are not used or credited in the SFP Boiling accident mitigation, and therefore, do not affect the defueled accident scenarios.
15
SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Reclassify all Safety Related Electrical SSCs to Non-Safety Related 202708042-03
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Description:==
This change will reclassify all safety related electrical SSCs from QC II (Class 1 E) to non-safety related QC III (non-Class 1E) or QCIII-AQ in 90034 (the Q-List). This change will additionally eliminate the applicability of General Design Criteria (GDC) 17 and 18 to SONGS. The commitment to regulatory guides and industry standards described in the UFSAR will no longer apply for maintaining compliance with GDC 17 and 18.
Evaluation Summary:
As determined by the engineering evaluation documented in NECP 801169870, in the permanently defueled condition there are no electrical SSCs that perform any specified safety functions in the current licensing basis.
Discussion - GDC 17 and Single Failure Criteria:
The determination that SONGS electrical distribution systems and components no longer perform safety functions is the basis for eliminating the applicability of General Design Criterion (GDC) 17 and the inherent single failure criteria.
10 CFR 50 Appendix A defines a single failure as follows:
"A single failure means an occurrence which results in the loss of capability of a component to perform its intended safety functions." Therefore, capability to withstand a single failure in electrical systems is a plant-specific design consideration, which ensures that a single failure does not result in a loss of the capability of the system to perform its safety function or functions.
General Design Criterion 17 - Electric Power Systems states: "An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents."
As previously discussed, in the permanently defueled condition there are no electrical SSCs which perform safety functions and none which are credited in supporting the mitigation of the remaining Chapter 15 accidents. Therefore, Criterion 17 of 10CFR50 Appendix A is no longer applicable to SONGS.
Discussion - GDC 18 General Design Criterion 18-Inspection and Testing of Electric Power Systems states:
"Electric power systems important to safety shall be designed to permit appropriate periodic inspection and testing of important areas and features, such as wiring, insulation, connections, and switchboards, to assess the continuity of the systems and the condition of their components. The systems shall be designed with a capability to test periodically (1) the operability and functional performance of the components of the systems, such as onsite power sources, relays, switches, and buses, and (2) the operability of the systems as a whole and, under conditions as close to design as practical, the full operation sequence that brings the systems into operation, including operation of applicable portions of the protection system, and the transfer of power among the nuclear power unit, the offsite power system, and the onsite power system."
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SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Reclassify all Safety Related Electrical SSC's to Non-safety related 202708042-03 (continued)
As previously discussed, in the permanently defueled condition there are no electrical SSCs which perform a safety function and none which are credited in supporting the mitigation of the remaining Chapter 15 accidents. Therefore, Criterion 18 of 10CFR50 Appendix A is no longer applicable to SONGS.
Auxiliary Feedwater System Permanent Removal From Service 202510710-08
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Description:==
On June 12, 2013, SCE formally notified the NRC that it has permanently ceased operation of Units 2 and 3 with the submittal of a Certification of Permanent Cessation of Operations.
Therefore the Auxiliary Feedwater system is no longer required to remain functional.
Evaluation Summary:
The Auxiliary Feedwater System will be permanently removed from service for the defueled condition. The Auxiliary Feedwater System is not credited for any accidents that are credible in the defueled mode. Any failure modes and effects described in the UFSAR are only analyzed for conditions other than defueled.
Coolant Radwaste System (CRS) Permanent Removal From Service 202846860-03
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Description:==
The proposed activity is a change to UFSAR Section 11.2 to document the removal from service of the Coolant Radwaste System (CRS) and the removal of resin from the various Ion Exchangers in the Coolant Radwaste System (CRS) and the Miscellaneous Liquid Waste System (MLWS). The CRS has been isolated from interfacing systems/sub-systems and the resin contained in Radwaste Primary Ion Exchangers (E081, E082), and Radwaste Secondary Ion Exchangers (E079, E080) has been removed. The resin contained in Miscellaneous Waste Ion Exchangers (E072, E073), and Miscellaneous Waste Condensate Ion Exchangers (E076, E077) has been removed and processed for offsite release/disposal. The Miscellaneous Liquid Waste subsystem remains in-service to collect and temporarily store radioactive liquid until processed for release in accordance with Offsite Dose Calculation Manual (ODCM) and 10CFR20 requirements. A skid-mounted liquid waste treatment system will be used for processing of radioactive liquid prior to release or offsite disposal.
Evaluation Summary:
The removal from service of the Coolant Radwaste System is acceptable for implementation.
With the Reactor Coolant System and the Chemical and Volume Control System drained and isolated, the design function of the Coolant Radwaste System is no longer required.
UFSAR 15.7.3.3 credits the Miscellaneous Liquid Waste System with the collection of spilled leakage following a tank rupture in the Auxiliary Building to prevent release to the environment.
Removal of the resin from the ion exchangers does not impact the ability of the MLWS to collect and store radioactive liquid. Therefore, the removal of the resin is acceptable.
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SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Delete Licensee Controlled Specifications 3.3.112 Fuel Handling Isolation Signal (FHIS) and 3.7.11 Fuel Handling Building Post-Accident Cleanup Filter System 202526642-11
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Description:==
The proposed activity will delete Licensee Controlled Specifications (LCS) 3.3.112 and 3.7.118.
This supports permanent removal from service of the Fuel Handling Isolation Signal (FHIS), the Fuel Handling Building Post-Accident Cleanup Units (PACU) and associated equipment.
Changes will be made to the appropriate Sections of the UFSAR to reflect removal of the FHIS and the PACU Units.
Evaluation Summary:
Deletion of Licensee Controlled Specifications 3.3.112 and 3.7.118, and removal from service of the Fuel Handling Isolation Signal and the Fuel Handling Building Post Accident Cleanup Units is acceptable for implementation. The Licensee Controlled Specifications require one train of FHIS and one train of PACUs to be OPERABLE during fuel movement, as originally designed for a fuel handling accident. However, the licensing bases in UFSAR Section 15.7.3.4 no longer credits the FHIS, or the PACU to prevent or mitigate the consequences of a fuel handling accident. No credit is taken for isolation or filtration in determining the dose consequences.
Without FHIS or the PACU, the dose consequence at the Exclusion Area Boundary during a fuel handling accident is 0.20 E-3 REM TEDE. This is less than 0.0032% of the Regulatory Guide 1,183 Acceptance Criteria of 6.3 REM TEDE and is unchanged by this proposed activity.
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SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Revise Licensee Controlled Specification (LCS) 3.7.106 Spent Fuel Pool (SFP) Operation 202534151-05
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Description:==
LCS 3.7.106 is being revised due to the permanent shut down of SONGS Units 2 and 3. The existing LCS assumes that the plant is still capable of being operated at full power. With the units permanently defueled and with the decay time of the fuel greater than 18 months, some of the existing requirements are overly restrictive and can be relaxed without increasing risk to the spent fuel pool system. The revised LCS provides adequate assurance that the SFP will meet all specified design requirements. The requirements for Operability (should be 'Functional) of Component Cooling Water and Salt Water Cooling systems will be changed to be able to perform their "specified function" only). Also, the diesels will need to be functional only (not operable) in a defueled mode. This change modifies LCS 3.7.106 to minimize the requirements for EDG functionality.
Evaluation Summary:
The significant proposed changes to LCS 3.7.106 are as follows:
- 1) Replacing the term "Operable" with "Functional" throughout LCS 3.7.106. This is consistent with the definition in RIS 2005-20.
- 2) Changing the definition of a full core off-load as defined in Note 1 from "A full core offload is the presence in the SFP of GTE 109 irradiated fuel assemblies moved from the reactor core during the current plant shutdown. The current plant shutdown ends when the plant transitions from Mode 6 to Mode 5" to "A full core offload is the presence in the SFP of GTE 109 irradiated fuel assemblies moved from the reactor core, with less than 18 months decay time." This change was necessary because the plant will no longer be transitioning from Mode 5 to Mode 6.
The "18 month decay time" was chosen because this is the approximate length of one fuel cycle. The LCS states "With a full core offload, the temperature of the SFP water shall be
< 160F. At other times, the temperature of the water shall be < 140F." Because the fuel in the SFP has had greater than 18 months of decay time, the lower temperature limit of 140F is now the applicable limit (ie, limit of 160F is no longer applicable), which is a change in the conservative direction.
- 3) Deleting all verbiage pertaining to Modes 1-6.
- 4) Redefining applicability from "At all times with irradiated fuel in the SFP" to "At all times with irradiated fuel in the SFP when pool water temperature has the capability to reaching 140F with no cooling." When the SFP no longer has the capability to reach 140 F with no cooling, fuel damage as a result of SFP boiling is no longer a concern.
- 5) Adding a new Note 2, "A SFP pump and heat exchanger may be considered operating while secured during planned SFP heat up tests as long as required Action B.2 is performed and pool water temperature does not exceed 140F." Similarly, replace Notes 2 and 3 and Parts of Note 1 on page 3.7-106-7 with a new note as follows: "It is recognized that SFP heat up tests will need to be periodically performed in order to validate assumptions and/or calculations. The LCS will continue to be met as long as pool temperature is being monitored in accordance with Action B.2 and pool temperature does not exceed 140F."
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SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Revise Licensee Controlled Specification (LCS) 3.7.106 202534151-05 (continued)
- 6) Redefining the surveillance requirements necessary for the EDGs to meet their specified function to support SFP operation. Previously, LCS 3.7.106 called out specific surveillances from the Technical Specifications in order to meet the SFP specified functions. These requirements are overly conservative to support the current SFP configuration. The new requirements will provide a reasonable expectation that the EDGs will be able to provide an alternative source of power as necessary to support SFP operations. The FSAR accident analysis for loss of SPF cooling does not take any credit for the EDGS, therefore listing the EDGs as an alternative power supply is conservative.
- 7) Eliminates some references that are no longer applicable.
- 8) States that "The CCW and SWC specified functions are to provide a decay heat removal mechanism. This specified function is satisfied when CCW is capable of providing a minimum flow of greater than or equal to 2950 gpm through the spent fuel heat exchangers and a heat removal path exists to the ultimate heat sink." The 2950 gpm value is the minimum flow currently allowed under procedure SO23-3-2.11, "Spent Fuel Pool Operations."
Changes 1, 2, 3, 4, and 7 did not constitute a change to the facility and as such, the questions on this evaluation were not applicable to those changes. There were no physical changes to the facility. The responses to each question for changes 5, 6, and 8 were NO, and as such, the above proposed changes are acceptable for implementation per the 50.59 process.
Gaseous Radwaste System Permanent Removal From Service 202526805-13
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Description:==
Permanently secure and remove from service the Gaseous Radwaste System. Make the necessary changes to UFSAR Section 11.3 to identify that the Gaseous Radwaste System has been permanently removed from service. The Gaseous Radwaste System is a sub-system of the Gaseous Waste Management Systems as described in UFSAR section 11.3. This Safety Evaluation only covers the removal from service of the Gaseous Radwaste System (UFSAR Section 11.3 Item A).
Evaluation Summary:
As a result of the permanent shutdown of SONGS Units 2 and 3, the systems and components which provide input to the Waste Gas Surge Tank (WGST) have been removed from service, isolated and drained. With all inputs to the Waste Gas System eliminated, the system has been isolated, the Waste Gas Surge Tanks and Decay Tanks have been released and purged with nitrogen, and the H2 concentration verified to be at 0%. The permanent removal from service is acceptable for implementation. With all inputs to the gaseous radwaste system permanently isolated, the contents of the system released, and the system purged, a release of radioactive gases due to a decay tank rupture or other means is no longer a credible accident.
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SAN ONOFRE NUCLEAR GENERATING STATION ENCLOSURE FACILITY CHANGE REPORT (FCR)
Shutdown Cooling System (SDC) Permanent Removal From Service 203086842-03
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Description:==
Remove Units 2 and 3 Shutdown Cooling System (SDC) from service. In addition to serving the reactor coolant system, the SDC was an alternate alignment available for normal spent fuel pool cooling during maintenance activities. The proposed activity is to completely drain the SDC and also remove hazards such as pump lubrication oil, chemicals, remove gas bottles, and isolate electrical power/open breakers in preparation for abandonment.
Evaluation Summary:
The SDC is not required to comply with the assumptions of NUREG-1 738 "Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants," and will be permanently removed from service for the defueled condition. Removing the SDC from service will not adversely impact the assumptions for the loss of spent fuel pool cooling accident.
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