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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217P7111999-10-26026 October 1999 Informs That Licensee 990330 Response to GL 97-06 Provides Reasonable Assurance That Condition of Licensee Steam Generator Internals Is in Compliance with Current Licensing Bases for Plant ML20217K3571999-10-21021 October 1999 Discusses Use of SONGS as Generic Safety Issue 191 Ref Plant.Future Requests for Info & Addl Coordination Activities Be Handled Through D Evans of Organization.With Diskette ML20217K8541999-10-21021 October 1999 Forwards Revised Pages to ERDS Data Point Library,Per Requirements of 10CFR50,App E,Section VI.3.a.Described Unit 2 & 3 Changes for 2/3R7813 Were Completed on 990924 ML20217L9491999-10-21021 October 1999 Forwards SONGS Emergency Response Telephone Directory, for Oct-Dec 1999 ML20217J8631999-10-15015 October 1999 Forwards Insp Repts 50-361/99-12 & 50-362/99-12 on 990808- 0918.One Violation Identified Involving Inoperability of Emergency Diesel Generator in Excess of Allowed Outage Time ML20217E3221999-10-13013 October 1999 Forwards MORs for Sept 1999 for Songs,Units 2 & 3.No Challenges Were Noted to Psvs for Either Units 2 or 3 ML20217E7671999-10-12012 October 1999 Forwards Rev 62 to NRC Approved Aug 1983, Physical Security Plan,Songs,Units 1,2 & 3, IAW 10CFR50.54(p).Changes,as Described in Encls 1 & 2,do Not Reduce Effectiveness of Plan.Encl Withheld,Per 10CFR73.21 ML20217B5981999-10-0606 October 1999 Informs That Staff Concluded That All Requested Info for GL 98-01, Year 2000 Readiness in Us Nuclear Power Plants, Provided for San Onofre Nuclear Generating Station,Units 2 & 3 ML20216H8741999-09-29029 September 1999 Provides Requested Written Response to GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal. Lab Testing of Charcoal Adsorber Samples for Creacus & Pacu Satisfies Listed Requirements ML20216H8541999-09-29029 September 1999 Submits Encl Request for Relief from ASME Code,Section III Requirements in 10CFR50.55(a)(3) to Use Mechanical Nozzle Seal Assembly as Alternate ASME Code Replacement at SONGS, Units 2 & 3 for Period of Operation Beginning with Cycle 11 ML20216J2631999-09-28028 September 1999 Forwards Copy of Final Accident Sequence Precursor (ASP) Analysis of Operational Event at Songs,Unit 2,reported in LER 361/98-003 ML20212H4461999-09-28028 September 1999 Forwards Suppl Info,As Discussed with NRC During 990812 Telcon,To Support Risk Informed Inservice Testing & GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs ML20212G5611999-09-24024 September 1999 Informs NRC That SCE Remains Committed to Performing Eddy Current Examinations of 100% of Reactor Vessel Head Penetrations at Songs,Unit 3.Exams Will Not Be Performed During Cycle 11 RFO 05000361/LER-1999-005, Forwards 30-day follow-up LER 99-005-00,describing Loss of Physical Train Separation in Control Room.Any Actions Listed Intended to Ensure Continued Compliance with Existing Commitments1999-09-23023 September 1999 Forwards 30-day follow-up LER 99-005-00,describing Loss of Physical Train Separation in Control Room.Any Actions Listed Intended to Ensure Continued Compliance with Existing Commitments ML20212D9921999-09-16016 September 1999 Informs That on 990818,NRC Staff Completed Midcycle PPR of San Onofre.Nrc Plan to Conduct Core Insps & One Safety Issues Evaluation of MOVs at Facility Over Next 7 Months. Details of Insp Plan Through March 2000 Encl ML20212A4061999-09-14014 September 1999 Forwards Revised Pages to ERDS Data Point Library.Described Unit 2 Changes for 2R7817 & 2R7828 Were Completed on 990818 & Unit 3 Change for 3R7828 Was Completed on 990903 ML20216E6031999-09-10010 September 1999 Provides Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams, Dtd 990820.Schedule Shown on Attachment 1, Operator Licensing Exam Data, Provides Util Best Estimate Through Cy 2003 ML20217B9011999-09-10010 September 1999 Responds to Which Addressed Concerns Re Y2K Issue & Stockpiling of Potassium Iodide (Ki) Tablets by Informing That San Onofre Nuclear Station Already Completed All Work Required to Be Ready for Y2K Transition ML20211K4191999-09-0303 September 1999 Final Response to FOIA Request for Documents.Documents Listed in App a Being Withheld in Part (Ref FOIA Exemptions 5 & 7) ML20211N0261999-09-0303 September 1999 Forwards Exemption from Certain Requirements of 10CFR50.44 & 10CFR50,app A,General Design Criterion 41 in Response to Util Request of 980910,as Supplemented 990719 & SER 05000206/LER-1999-001, Forwards LER 99-001-00 for Occurrence Re Unattended Security Weapon Inside Protected Area.Single Rept for Unit 1 Is Being Submitted,Iaw NUREG-1022,Rev 1,since Condition Involves Shared Sys & Is Applicable to Units 1,2 & 31999-08-31031 August 1999 Forwards LER 99-001-00 for Occurrence Re Unattended Security Weapon Inside Protected Area.Single Rept for Unit 1 Is Being Submitted,Iaw NUREG-1022,Rev 1,since Condition Involves Shared Sys & Is Applicable to Units 1,2 & 3 ML20211H3321999-08-30030 August 1999 Discusses 1999 Emergency Preparedness Exercise Extent of Play & Objectives.Based on Review,Nrc Has Determined That Exercise Extent of Play & Objectives Are Appropriate to Meet Emergency Plan Requirements ML20211J7151999-08-27027 August 1999 Forwards Insp Repts 50-361/99-09 & 50-362/99-09 on 990627- 0807.Two Violations Being Treated as non-cited Violations ML20211H8561999-08-23023 August 1999 Forwards SE Accepting Licensee 970625 Requests for Relief RR-E-2-03 - RR-E-2-04 from Exam Requirements of Applicable ASME Code,Section Xi,For First Containment ISI Interval ML20211J5821999-08-23023 August 1999 Corrected Copy of ,Changing Application Date from 970625 to 990625.Ltr Forwarded SE Accepting Licensee 990625 Requests for Relief RR-E-2-03 - RR-E-2-08 from Exam Requirements of Applicable ASME Code,Section XI as Listed ML20210V4271999-08-16016 August 1999 Forwards Proprietary Certified Renewal Applications for SROs a Harkness,R Grabo & T Vogt & RO D Carter,Submitted on Facsimile Form NRC-398 & Certified NRC Form 396.Encls Withheld ML20210R6681999-08-13013 August 1999 Forwards Response to NRC RAI Re SCE License Amend Applications 173 & 159 for Songs,Units 2 & 3,proposed Change Number 485,which Requests Addition of SR to TS 3.3.9, CR Isolation Signal ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ML20210Q6451999-08-12012 August 1999 Forwards Monthly Operating Repts for July 1999 for SONGS, Units 2 & 3,per TS 5.7.1.4.There Were No Challenges to Pressurizer Safety Valves for Either Units ML20210P5711999-08-11011 August 1999 Forwards Amend Application Number 189 for License NPF-10 & Amend Application Number 174 to License NPF-15,replacing Analytical Limits Currently Specified as Acceptance Criteria with Allowable Values,Per Encl Calculation E4C-098 ML20210P4681999-08-11011 August 1999 Forwards COLR for Cycle 10 for Songs,Units 2 & 3,IAW TS Section 5.7.1.5.d, Colr. Changes to COLR Parameters Have Been Conducted IAW Approved COLR Methodologies & All Applicable Limits of Safety Analysis Were Met ML20210P6221999-08-10010 August 1999 Forwards Replacement Pages for Attachments E & F of Amend Application Numbers 168 & 154 for Songs,Units 2 & 3.Pages Are Provided to Correct Errors to Pagination & Headings in 970618 Submittal ML20210N9721999-08-10010 August 1999 Responds to Appeal of FOIA Request for Documents Re Osre Issue.No Osre Visit Scheduled for Sept 1996 at Plant,Per 990722 Telcon.V Dricks,In Ofc of Public Affairs Should Be Contacted Re Osre Issue ML20210N0901999-08-0909 August 1999 Informs That 990312 Application Requested Amends to Licenses DPR-13,NPF-10 & NPF-15,respectively,being Treated as Withdrawn.Proposed Change Would Have Modified Facility TSs Pertaining to SONGS Physical Security Plan ML20210N5051999-08-0909 August 1999 Forwards Cycle 10 Update to TS Bases,Which Have Been Revised Between 980101-990630,per 10CFR50.71(e) 05000361/LER-1999-004, Forwards LER 99-004-00 Re Automatic Tgis Actuation.Event Affected Units 2 & 3 Equally Because Tgis Is Shared Sys. Single Rept Is Being Provided for Unit 2 IAW NUREG-1022, Rev 1.No New Commitments Are Contained in Encl1999-08-0606 August 1999 Forwards LER 99-004-00 Re Automatic Tgis Actuation.Event Affected Units 2 & 3 Equally Because Tgis Is Shared Sys. Single Rept Is Being Provided for Unit 2 IAW NUREG-1022, Rev 1.No New Commitments Are Contained in Encl ML20210L2311999-08-0505 August 1999 Forwards ISI Summary Rept,Including Owners Repts of Repairs & Replacements,For Songs,Unit 3.Rept Covers 970916 Through 990509,date Unit 3 Returned to Service Following Cycle 10 Refueling Outage ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ML20216D9671999-07-29029 July 1999 Provides Response to RAI to Support Proposed TS Change 460 Re Containment Isolation Valve Completion Time for SONGS, Units 2 & 3.Rev 3 to Abnormal Operating Instruction SO23-13-14, Reactor Coolant Leak, Encl ML20210C1821999-07-22022 July 1999 Forwards Rept Providing Results of Insp of Eggcrate Tube Supports Done on Secondary Side of Sgs,Using Remote Controlled Visual Equipment ML20210B2451999-07-21021 July 1999 Forwards Response to NRC 990615 RAI Re GL 95-07, Pressure Locking & Thermal Bldg of SR Power-Operated Gate Valves, for Songs,Units 2 & 3 ML20210B9891999-07-20020 July 1999 Ack Receipt of Transmitting Plant Emergency Plan Implementing Procedure SO123-VIII-1, Recognition & Classification of Emergencies ML20209J5241999-07-19019 July 1999 Provides Clarification of Util Intentions Re Disposition of Systems for Which Exemption & TS Changes Were Requested in Licensee .Deferment of Action Re Hydrogen Monitors,Encl ML20210N2881999-07-19019 July 1999 Forwards Rev 61 to Physical Security Plan,Rev 21 to Safeguards Contingency Plan & Rev 20 to Security Force Training & Qualification Plan,Per 10CFR50.54(p),for Plant. Screening Criteria Forms Encl.Plans Withheld ML20210A2911999-07-19019 July 1999 Submits Withdrawal Request Submitted by Ltr Dtd 990312, Requesting NRC Approval of Revs to Physical Security Plan & Safeguards Contingency Plan Tactical Response Plan ML20209G3421999-07-15015 July 1999 Forwards Table of 16 Affected Tube Locations in SG E089, Discovered During Cycle 10 Outage Insp,Which Were Probably Not Examined by Bobbin During Cycle Outage Insp ML20209D8051999-07-12012 July 1999 Discusses Licensee Response to RAI Re GL 92-01,Rev 1,Suppl 1, Rc Structural Integrity, Issue on 950519 to Plant. NRC Revised Info in Reactor Vessel Integrity Database & Is Releasing It as Rvid Version 2 ML20209F5681999-07-0909 July 1999 Forwards Insp Repts 50-361/99-08 & 50-362/99-08 on 990516- 0626.One Violation Identified & Being Treated as Noncited Violation,Consistent with App C of Enforcement Policy ML20209C1571999-07-0202 July 1999 Forwards Response to NRC RAI Re SCE Submittal Dtd 980710,re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions ML20196K6721999-07-0202 July 1999 Discusses 990628 Meeting Conducted in Region IV Office Re Status of San Onofre Nuclear Generating Station Emergency Preparedness Program.List of Attendees & Licensee Presentation Encl 1999-09-03
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217L9491999-10-21021 October 1999 Forwards SONGS Emergency Response Telephone Directory, for Oct-Dec 1999 ML20217K3571999-10-21021 October 1999 Discusses Use of SONGS as Generic Safety Issue 191 Ref Plant.Future Requests for Info & Addl Coordination Activities Be Handled Through D Evans of Organization.With Diskette ML20217K8541999-10-21021 October 1999 Forwards Revised Pages to ERDS Data Point Library,Per Requirements of 10CFR50,App E,Section VI.3.a.Described Unit 2 & 3 Changes for 2/3R7813 Were Completed on 990924 ML20217E3221999-10-13013 October 1999 Forwards MORs for Sept 1999 for Songs,Units 2 & 3.No Challenges Were Noted to Psvs for Either Units 2 or 3 ML20217E7671999-10-12012 October 1999 Forwards Rev 62 to NRC Approved Aug 1983, Physical Security Plan,Songs,Units 1,2 & 3, IAW 10CFR50.54(p).Changes,as Described in Encls 1 & 2,do Not Reduce Effectiveness of Plan.Encl Withheld,Per 10CFR73.21 ML20216H8741999-09-29029 September 1999 Provides Requested Written Response to GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal. Lab Testing of Charcoal Adsorber Samples for Creacus & Pacu Satisfies Listed Requirements ML20216H8541999-09-29029 September 1999 Submits Encl Request for Relief from ASME Code,Section III Requirements in 10CFR50.55(a)(3) to Use Mechanical Nozzle Seal Assembly as Alternate ASME Code Replacement at SONGS, Units 2 & 3 for Period of Operation Beginning with Cycle 11 ML20212H4461999-09-28028 September 1999 Forwards Suppl Info,As Discussed with NRC During 990812 Telcon,To Support Risk Informed Inservice Testing & GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Movs ML20212G5611999-09-24024 September 1999 Informs NRC That SCE Remains Committed to Performing Eddy Current Examinations of 100% of Reactor Vessel Head Penetrations at Songs,Unit 3.Exams Will Not Be Performed During Cycle 11 RFO 05000361/LER-1999-005, Forwards 30-day follow-up LER 99-005-00,describing Loss of Physical Train Separation in Control Room.Any Actions Listed Intended to Ensure Continued Compliance with Existing Commitments1999-09-23023 September 1999 Forwards 30-day follow-up LER 99-005-00,describing Loss of Physical Train Separation in Control Room.Any Actions Listed Intended to Ensure Continued Compliance with Existing Commitments ML20212A4061999-09-14014 September 1999 Forwards Revised Pages to ERDS Data Point Library.Described Unit 2 Changes for 2R7817 & 2R7828 Were Completed on 990818 & Unit 3 Change for 3R7828 Was Completed on 990903 ML20216E6031999-09-10010 September 1999 Provides Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams, Dtd 990820.Schedule Shown on Attachment 1, Operator Licensing Exam Data, Provides Util Best Estimate Through Cy 2003 05000206/LER-1999-001, Forwards LER 99-001-00 for Occurrence Re Unattended Security Weapon Inside Protected Area.Single Rept for Unit 1 Is Being Submitted,Iaw NUREG-1022,Rev 1,since Condition Involves Shared Sys & Is Applicable to Units 1,2 & 31999-08-31031 August 1999 Forwards LER 99-001-00 for Occurrence Re Unattended Security Weapon Inside Protected Area.Single Rept for Unit 1 Is Being Submitted,Iaw NUREG-1022,Rev 1,since Condition Involves Shared Sys & Is Applicable to Units 1,2 & 3 ML20210V4271999-08-16016 August 1999 Forwards Proprietary Certified Renewal Applications for SROs a Harkness,R Grabo & T Vogt & RO D Carter,Submitted on Facsimile Form NRC-398 & Certified NRC Form 396.Encls Withheld ML20210R6681999-08-13013 August 1999 Forwards Response to NRC RAI Re SCE License Amend Applications 173 & 159 for Songs,Units 2 & 3,proposed Change Number 485,which Requests Addition of SR to TS 3.3.9, CR Isolation Signal ML20210Q6451999-08-12012 August 1999 Forwards Monthly Operating Repts for July 1999 for SONGS, Units 2 & 3,per TS 5.7.1.4.There Were No Challenges to Pressurizer Safety Valves for Either Units ML20210P5711999-08-11011 August 1999 Forwards Amend Application Number 189 for License NPF-10 & Amend Application Number 174 to License NPF-15,replacing Analytical Limits Currently Specified as Acceptance Criteria with Allowable Values,Per Encl Calculation E4C-098 ML20210P4681999-08-11011 August 1999 Forwards COLR for Cycle 10 for Songs,Units 2 & 3,IAW TS Section 5.7.1.5.d, Colr. Changes to COLR Parameters Have Been Conducted IAW Approved COLR Methodologies & All Applicable Limits of Safety Analysis Were Met ML20210P6221999-08-10010 August 1999 Forwards Replacement Pages for Attachments E & F of Amend Application Numbers 168 & 154 for Songs,Units 2 & 3.Pages Are Provided to Correct Errors to Pagination & Headings in 970618 Submittal ML20210N5051999-08-0909 August 1999 Forwards Cycle 10 Update to TS Bases,Which Have Been Revised Between 980101-990630,per 10CFR50.71(e) 05000361/LER-1999-004, Forwards LER 99-004-00 Re Automatic Tgis Actuation.Event Affected Units 2 & 3 Equally Because Tgis Is Shared Sys. Single Rept Is Being Provided for Unit 2 IAW NUREG-1022, Rev 1.No New Commitments Are Contained in Encl1999-08-0606 August 1999 Forwards LER 99-004-00 Re Automatic Tgis Actuation.Event Affected Units 2 & 3 Equally Because Tgis Is Shared Sys. Single Rept Is Being Provided for Unit 2 IAW NUREG-1022, Rev 1.No New Commitments Are Contained in Encl ML20210L2311999-08-0505 August 1999 Forwards ISI Summary Rept,Including Owners Repts of Repairs & Replacements,For Songs,Unit 3.Rept Covers 970916 Through 990509,date Unit 3 Returned to Service Following Cycle 10 Refueling Outage ML20216D9671999-07-29029 July 1999 Provides Response to RAI to Support Proposed TS Change 460 Re Containment Isolation Valve Completion Time for SONGS, Units 2 & 3.Rev 3 to Abnormal Operating Instruction SO23-13-14, Reactor Coolant Leak, Encl ML20210C1821999-07-22022 July 1999 Forwards Rept Providing Results of Insp of Eggcrate Tube Supports Done on Secondary Side of Sgs,Using Remote Controlled Visual Equipment ML20210B2451999-07-21021 July 1999 Forwards Response to NRC 990615 RAI Re GL 95-07, Pressure Locking & Thermal Bldg of SR Power-Operated Gate Valves, for Songs,Units 2 & 3 ML20210A2911999-07-19019 July 1999 Submits Withdrawal Request Submitted by Ltr Dtd 990312, Requesting NRC Approval of Revs to Physical Security Plan & Safeguards Contingency Plan Tactical Response Plan ML20210N2881999-07-19019 July 1999 Forwards Rev 61 to Physical Security Plan,Rev 21 to Safeguards Contingency Plan & Rev 20 to Security Force Training & Qualification Plan,Per 10CFR50.54(p),for Plant. Screening Criteria Forms Encl.Plans Withheld ML20209J5241999-07-19019 July 1999 Provides Clarification of Util Intentions Re Disposition of Systems for Which Exemption & TS Changes Were Requested in Licensee .Deferment of Action Re Hydrogen Monitors,Encl ML20209G3421999-07-15015 July 1999 Forwards Table of 16 Affected Tube Locations in SG E089, Discovered During Cycle 10 Outage Insp,Which Were Probably Not Examined by Bobbin During Cycle Outage Insp ML20209C1571999-07-0202 July 1999 Forwards Response to NRC RAI Re SCE Submittal Dtd 980710,re GL 96-06, Assurance of Equipment Operability & Containment Integrity During Design-Basis Accident Conditions ML20210N9871999-07-0101 July 1999 Appeals Denial of Documents Re Sept 1996 Osre for San Onofre Nuclear Generating Station.Requests Copies of Sept 1996 Osre Rept & Any More Recent Osre Repts ML20209B3571999-06-28028 June 1999 Submits Response to GL 98-01,Suppl 1 Y2K Readiness of Computer Sys at Nuclear Power Plants. GL 98-01 Requested Response on Status of Facility Y2K Readiness by 990701. Disclosure Encl ML20209B4831999-06-25025 June 1999 Requests NRC Approval of Six Relief Requests from ASME Code Requirement for Containment ISI Exams.Six Relief Requests, Provided as Enclosures 1-6,are as Listed ML20196A9801999-06-17017 June 1999 Responds to NRC 990420 RAI Re Proposed risk-informed Inservice Testing & GL 96-05 Programs at Songs,Units 2 & 3. Revised Pages to risk-informed Inservice Testing Program, Encl ML20195G8091999-06-14014 June 1999 Forwards Response to RAI Made During 990511 Telcon Re LARs 184 & 170 for SONGS Units 2 & 3.Amend Applications Proposed Restriction on Operation with Channel of RAS or Efas in Tripped Condition ML20195K4201999-06-11011 June 1999 Forwards LERs 99-003-00 & 99-004-00 Re Manual Esfas (Reactor Trips) Due to Problems with Main Feedwater Control.Two Events Are Being Reported Separately Because Actual Causes Are Considered Different & Independent of Each Other ML20195H1561999-06-10010 June 1999 Forwards MORs for May 1999 for Songs,Units 2 & 3.There Were No Challenges to Pressurizer Safety Valves for Either Unit 2 & 3 ML20195E4981999-06-0808 June 1999 Forwards Application for Amends 188 & 173 to Licenses NPF-10 & NPF-15 for SONGS Units 2 & 3,respectively.Amends Would Revise TS 3.5.2,3.1.9,3.7.1 & 5.1.7.5 Re Small Break LOCA Charging Flow & Main Steam Safety Valve Setpoints ML20196L3191999-05-24024 May 1999 Forwards ISI Summary Rept,Including Owners Repts of Repairs & Replacements for Songs,Unit 2.Rept Covers Period of 970916-990226 ML20207A3831999-05-24024 May 1999 Responds to NRC 990326 RAI on DG Srs.Proposed to Add Listed Sentence to TS Bases for SRs 3.8.1.7,3.8.1.12 & 3.8.1.15,as Result of Discussion with NRC During 990427 Telcon ML20211K4261999-05-18018 May 1999 FOIA Request for Documents Re San Onofre OI Repts 4-98-041, 4-98-043 & 4-98-045 ML20206S7161999-05-17017 May 1999 Forwards MORs for Apr 1999 for Songs,Units 2 & 3.There Were No Challenges to Pressurizer Safety Valves for Either Unit 2 or 3 ML20206N4711999-05-13013 May 1999 Provides Info Requested by NRC Re Reduced Pressurizer Water Vol Change Amends Application 172 & 158 for Songs,Units 2 & 3,respectively.Proposed Change Will Reduce Pressurizer Water Level Required for Operability ML20206M7791999-05-13013 May 1999 Informs NRC of Changes Being Made to Emergency Response Data Sys (ERDS) at SONGS Unit 3.Revised Page to ERDS Data Point Library Is Provided in Encl ML20206K6891999-05-11011 May 1999 Forwards Approved Amends to NPDES Permits CA0108073,Order 94-49 & CA0108181,Order 94-50 & State Water Resources Board Resolution ML20206M0681999-05-10010 May 1999 Submits Correction to Info Contained in Licensee to NRC Re Proposed TS Change Number NPF-10/15-475.Stated Info Was Incorrect in That Overtime Provisions Were Not Contained in TR at Time of Was Submitted ML20206H0451999-05-0404 May 1999 Forwards Annual Financial Repts for Listed Licensees of Songs,Units 1,2 & 3.Each Rept Includes Appropriate Certified Financial Statement Required by 10CFR50.71(b) ML20206H1931999-05-0303 May 1999 Forwards 1998 Annual Rept, for SONGS Units 2 & 3 & PVNGS Units 1,2 & 3.SCEs Form 10K Annual Rept to Securites & Exchange Commission for Fiscal Yr Ending 981231,encl ML20206C5151999-04-29029 April 1999 Forwards 1998 Radiological Environ Operating Rept for Songs,Units 1,2 & 3. Annual Radiological Environ Operating Rept Covers Operation of Songs,Units 1,2 & 3 During CY98 & Includes Summaries Interpretations & Analysis of Trends ML20206E5851999-04-29029 April 1999 Forwards Annual Radioactive Effluent Release Rept for 1998 for SONGS Units 1,2 & 3. Also Encl Are Rev 13 to Unit 1 ODCM & Rev 31 to Units 2 & 3 Odcm 1999-09-29
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t e 4 Southem Califomia Edison Campany 23 PARKER STREET BRVINE, CALIFORNIA 92718 f
WALTER C. MARSH April 17,1995 m - ~E MANAGER OF NUCLE. AR REGULATORY AFF AIRS (714)454-440"3 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:
Subject:
Docket No. 50-361 and 50-362 Application of Leak-Before-Break Technology to Reactor Coolant System Piping San Onofre Nuclear Generating Station i Units 2 and 3 The purpose of this letter is to inform the NRC of Southern California Edison's (Edison's) intent to eliminate the dynamic effects associated with high energy pipe ruptures in the Reactor Coolant System (RCS) piping from the licensing and desig(n Leak-Before-Break bases LBB) of San This technology. Onofre changeUnitsto2the and 3 by application of the licensin bases is permitted by revised General Design Criterion 4 (GDC-4)g and design of Appendix A to 10 CFR 50. By this letter NRC approval is requested by the end of 1995 to allow Edison to start using LBB technology during the Unit-2 C outage to 1) remove pipe whip restraints from the RCS loop,eliminate 2)ycle 9.jet refueling impingement loads from the RCS piping and branch lines connected to the RCS, and 3) relax the in-service testing criteria for the Reactor Coolant Pump snubbers'and Steam Generator hydraulic snubbers.
On October 30, 1990, the NRC staff, in its Safety Evaluation for Topical Report CEN-367, " Leak-Before-Break Evaluation of Primary Loop Piping in Combustion Engineering Designed Nuclear Steam Supply Systems," accepted referencing CEN-367 as a technical tasis for applying LBB technology to primary loop piping. The acceptd version of the topical report was issued as CEN-367-A in February 1991, fa a condition of referencing CEN-367 the NRC requires licensees, as stated in Section 3.0 of the NRC Safety Evaluation, to
" submit information to demonstrate that leakage detection systems installed at the specific facility are consistent with Regulatory Guide 1.45," which is titled " Reactor Coolant System Pressure Boundary Leakage Detection Systems."
Edison evaluated the existing radiation monitoring and RCS leakage detection systems at San Onofre Units 2 and 3 and concluded the installed leakage detection' systems are consistent with Regulatory Guide (RG) 1.45. Specific details are provided in the enclosure to this letter which includes a summary of Edison's compliance with the RG 1.45 positions. Additionally, a Design Change Package is in progress to replace the existing gas channel monitor with a state-of-the-art, more responsive design. It is Edison's intent to implement this design change by the end of 1996.
T ". C " ' q 9504190195 950417 i PDR ADOCK 05000361 .
P PDR I
. I f ~~
Do'cument Control Desk If you have any questions regarding this submittal, please let me know.
t Very truly yours, h0 i
i r
cc: L. J. Callan ~, Regional Administrator, NRC RegionLIV i A. B. Beach, Director, Division of Reactor. Projects, Region IV K. E. Perkins, Jr., Director, Walnut Creek. Field Office, NRC Region IV l; J. A. Sloan, NRC Senior Resident' Inspector, San Onofre Units 2 and 3 M. B. Fields, NRC. Project Manager, San Onofre Units 2 and 3 ,
l l
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,. Enclosure APPLICATION OF LEAK-BEFORE-BREAK (LBB) TECHNOLOGY TO SAN ONOFRE UNITS 2 AND 3
'I . Background The October 30, 1990 NRC Safety Evaluation Report (SER) approving CEN-367, " Leak-Before-Break Evaluation of Primary Loop Piping in Combustion Engineering Designed Nuclear Steam Supply Systems," states "The revised GDC-4 is based on the development of advanced fracture mechanics techno'ogy using the LBB concept. On October 27, 1987, a final rule was published (52 B 41228), effective November 27, 1987, amending GOC-4 to 10 CFR 50. The revised GDC-4 allows the use of analyses to eliminate from the design bases the dynamic effects of postulated pipe ruptures in high energy piping in nuclear power units.
The new technology reflects an engineering advancement which allows simultaneously u, increase in safety, reduced worker radiation exposures, and loser construction and maintenance costs. Implementation permits the reinoval of pipe whip restraints and jet impingement barriers as well as other related changes in operating power plants, plants under construction, and future plant designs. Although functional and performance requirements for containments, emergency core cooling systems, and environmental qualification of equipment remain unchanged, local dynamic effects uniquely associated with postulated ruptures in piping which qualified for LBB may be excluded from the design basis (53 8 11311)."
The Combustion Engineering Owners Group (CE0G) submitted CEN-367 for NRC review on November 20, 1987. Edison was a participating member of the CE0G and San Onofre Units 2 and 3 were included in the bounding analyses of CEN-367. On October 30, 1990, the NRL accepted CEN-367. The Safety Evaluation Report (SER) accepting CEN-367 concluded that the subject CE0G primary loop piping complies with revised GDC-4 according to the criteria in NUREG-1061, Volume 3, " Report of the U. S. Nuclear Regulatory Commission Piping Review Committee, Evaluation for Potential for Pipe Breaks," November 1984. Thus, the probability or likelihood of large pipe breaks occurring in the primary coolant system loops of the subject CE0G plants is sufficiently low such that the dynamic effects associated with postulated pipe breaks need not be included in the l design basis. However, when referencing CE0G Topical Report CEN-367-A as a technical basis for applying LBB to primary loop piping licensees l must submit information which demonstrates that leakage detection systems installed at specific facility are consistent with Regulatory Guide (RG) 1.45, " Reactor Coolant System Pressure Boundary Leakage i Detection Systems."
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. l I I.. Evaluation of the Leakaae Detection Systems A. Purpose The purpose San Onofre of this Units evaluation 2 and 3 Reactor is to analym Coolant the Boundary Pressure capabilityRCPB)
(of the '
leak detection systems to meet Regulatory Guide (RG) 1.45,
" Reactor Coolant System Pressure Boundary Leakage Detection Systems."
- 8. Background A limited amount of leakage is expected from pressure-containing '
components forming the RCPB which consists of the reactor coolant system (RCS) and associated components. Components subject to leakage include valves, pump shaft seals, valve stem packing, :
flanges, and gaskets. RG 1.45 requires this type of leakage, to j the extent practical, be monitored, limited, and isolated from containment by routing, collecting, and monitoring in closed systems, such as tanks or sumps. This type of leakage is termed
" identified leakage," and is separated from any other type of ,
leakage which is termed " unidentified leakage." Unidentified '
leakage, which includes steam generator or tube sheet and intersystem leakage, etc., is monitored by several methods / devices as required by RG 1.45. The leakage detection system is-designed I to identify changes in unidentified leakage.
RG 1.45 requires three methods for monitoring RCPB leakage into -
containment. Two methods which are specified by RG 1.45 are 1) containment sump level / inlet flow rate and 2) containment airborne ,
particulate radioactivity. The third method was left for the licensee to choose from either one of the two methods given in RG 1.45. The third method chosen by Edison for monitoring RCPB leakage was containment airborne gaseous activity.
C. Consistency with Regulatory Guide 1.45 The Technical Specifications (TSs) provide part of the technical basis for the San Onofre Units 2 and 3 operating licenses.
Section 3/4.4.5.1 of the TSs Bases states:
"The RCS leakage detection systems required by this specification are provided to monitor and detect leakage from the Reactor Coolant Pressure Boundary. These detection systems are consistent with the recommendations of Regulatory Guide 1.45, ' Reactor Coolant System Pressure Boundary Leakage Detection Systems,' May 1973."
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The RCS leakage detection systems are also described in the San Onofre Units 2 and 3 Updated Final Safety Analysis Report (UFSAR) i Section 5.2.5 which states in part: J
...For leaks of 1 gal / min or greater, other than controlled l leakage sources, the RCPB leak detection systen is capable l
of detecting leakage and of determining the leakage rate as l required by NRC General Design Criterion 30."
"The RCPB leak detection system provides means for identifying the source for reactor coolant leakage to the '
extent practicable as required by NRC General Design Criterion 30." i "The RCPB leak detection system is consistent with the recommendations of NRC Regulatory Guide 1.45."
The design of the San Onofre leakage detection systems was ,
evaluated and accepted by the NRC as documented in NUREG-0712, ,
" Safety Evaluation Report related to the operation of San Onofre Nuclear Generating Station Units 2 and 3," dated February 1981.
Section 5.2.5 of this Safety Evaluation Report states in part:
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...The RCPB leakage detection systems are diverse and the applicants' design conforms to the requirements of Regulatory Guide 1.45 as noted above." ,
' l "We conclude that the San Onofre 2 and 3 design provides i reasonable assurance that primary system leakage will be i detected as required by General Design Criterion 30 and is !
- acceptable."
D. San Onofre Compliance with Regulatory Guide 1.45 The intent of the Regulatory Positions in RG 1.45 are met by the San Onofre Units 2 and 3 leakage detection systems. Table 1 summarizes the method of Edison's compliance to RG 1.45.
Regulatory Positions C.1, C.2, C.3, C.4, C.6, C.8, and C.9 are met without exceptions. Regulatory Positions C.5 and C.7 are met by i
alternative methods of compliance which are justified and )
discussed below: 4 o Regulatory Position C.5 requires the sensitivity and response time of each detection system for unidentified leakage to be adequate to detect a leakage rate, or its equivalent, of 1 gpm in one hour or less. For San Onofre Units 2 and 3, the particulate channel and sump level / flow methods of detection have the capability of detecting 1 gpm in liquid leakage within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Compared to the
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. . particulate channel, the gas channel method of leakage detection is less responsive due to the long half-life (5.3 days) of the predominant noble gas isotope (133Xe) in the reactor coolant. The existing gas channel response time has been estimated to range from 10 to 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> depending on i
length of operation, percent failed fuel, and the background l noble gas concentrations inside containment.
l l However, the gas channel is more responsive to leakage from l the pressurizer steam space due to noble gas concentrations i in the pressurizer steam space reaching concentrations up to i 25 times that in the liquid coolant. The gas channel is l capable of detecting pressurizer steam space leakage rates as low as 1 gpm within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
The shortcomings of the gas channel method of leakage i
detection had been acknowledged by the NRC staff in a l memorandum dated June 5, 1978, from P. Gurney (Reactor Systems Branch) to T. Novak, Chief (Reactor Systems Branch),
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Subject:
" Radiation Monitor Response for Reactor Coolant 1 Pressure Boundary Leakage Detection." The memorandum l recognizes that factors exist which "...by themselves or in the right combination can render the radiation monitors ,
useless as leak detectors." These factors include RCS activity, background radiation levels, isotope plateout, and alarm setpoints.
The Instrumentation Society of America (ISA) in Standard ISA-S67.03, " Standard for Light Water Reactor Coolant Pressure Boundary Leak Detection," 1982, Section 2, also acknowledges the shortcomings of leak detection systems and states "... It is recognized that some systems other'than sump monitoring may not be capable of meeting the requirements during certain plant operating conditions. In these cases, these systems shall be designed for leakage sensitivity as high as reasonably achievable."
The existing Units 2 and 3 leakage detection systems are designed for leakage sensitivity as high as reasonably achievable which meets the intent of RG 1.45, Position C.5.
Additionally, a Design Change Package is in progress to replace the existing gas channel monitor with a state-of-the-art, more responsive design. It is Edison's intent to implement this design change by the end of 1996.
o Regulatory Position C.7 requires that indicators and alarms for each leakage detection system should be provided in the
- main control room, procedures for converting various indicators to a common leakage equivalent should be available to operators, and calibration of these indicators should account for needed independent variables.
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The intent of Regulatory Position C.7 related to procedural requirements is met by a justifiable alternative.
Converting radiation monitor channel readings to a " common leakage equivalent," does not exist in procedures because alarms for leakage detection are provided by systems other than the leakage detection systems themselves. The results of Edison engineering calculation A-92-J-002 indicate that the relationship between changes in gas or particulate radiation monitor readings and changes in Reactor Coolant System (RCS) leakage depend on a number of factors which are subject to change with time. Radiation monitor reading changes do not have a direct correlation with RCS changes.
Radiation monitor indications of increases in RCS leakage are used to initiate specific actions but not for quantifying RCS leakage. This is due to the dependence of the indications / readings on a number of plant operating conditions and the general uncertainty of the results from the conversion of these readings to equivalent leakage.
As an alternative method, upon activation of a high activity alarm or operator knowledge of a trend indicative of increasing RCS leakage, San Onofre Units 2 and 3 procedures direct and provide operators the methods for locating and quantifying the leakage system by system (e.g , RCS, Chemical & Volume Control, or Steam Generator). The procedure additionally requires that a liquid inventory balance be performed.
The Regulatory Position C.7 alarm requirement for leakage detection is met by transmitting alarm signals provided by other systems to the annunciator and computer systems. The alarms in these other systems have their own design bases requirements distinct from the leakage detection systems.
As such, these alarms are not seismically qualified for the purpose of leak detection, but the leak detection monitors and their meters and recorders are seismically qualified as required by Regulatory Position C.6. Therefore, indications of changes in containment sump level and particulate / gas channel readings would be available to the operators following a seismic event. The operating procedures for a seismic event require immediate action to perform a RCPB leakage evaluation which does not depend on leak detection system alarms. Activation of any specific set of {
alarms / indications on the Seismic Instrument panel L-167 I requires surveillances for identifying and quantifying any increase in RCPB leakage. If the seismic indication / alarm involves an operating basis earthquake (0BE) or greater, procedures require a thorough inspec'c ion of the RCS, steam generators, reactor coolant pumps, and all RCS piping. <
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. The Regulatory Position C.7 requirement to account for i
needed independent variables in the calibration of the indicators is met without exception.
E. Conclusions The requirements for the leakage detection systems are included in the Technical Specifications for San Onofre Units 2 and 3. The ,
leakage detection systems were evaluated by the NRC during the original plant licensing and were determined to meet the '
guidelines of Regulatory Guide 1.45. Since San Onofre Units 2 and 3 are bounded by the CE0G analyses and the leakage detection systems are capable of detecting the specified leakage rate, the dynamic effects associated with postulated pipe breaks in the primary coolant system piping can be excluded from the licensing and design basis for the San Onofre units.
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TABLE 1
- SU M RY OF THE REGULATORY GUIDE 1.45 COMPLIANCE San Onofre Units 2 and 3 REGULATORY RG 1.45 POSITION COMPLIANCE METHOD OF COMPLIANCE REFERENCES C.1 Yes. No RCS liquid inventory control; UFSAR Sections exception. Containment sump flow rate 5.2.5.1.5 and and level. 5.2.5.1.3 C.2 Yes. No Containment atmosphere UFSAR Sections exception. radiation indicators; 5.2.5.2.1 and Containment area sump and 5.2.5.4 level instrumentation.
C.3 Yes. No Containment sump and flow UFSAR Sections exception monitoring; airborne gaseous 5.2.5.1 and and particulate radioactivity 5.2.5.2 monitoring. ?
C.4 Yes. No Decreasing Volume Control UFSAR Section exception. Tank level; increasing 5.2.5.1.11 charging flow rate; t increasing Component Cooling Water radioactivity.
l C.5 Intent met. Monitor sensitivity and NRC Interoffice
[ Alternative response time met NRC memorandum dated
! justified, expectations. A design 6/5/78, Edison improvement is in process. Calculation l
A-92-J-002 C.6 Yes. No Leak detection systems and San Onofre Units exception. their indications are 2/3 Consolidated seismically qualified and Control Data will perform their intended Base Instrument functions regardless of Index 90010A operating conditions of any ,
associated alarm features. l C.7 Intent met. Procedures direct and provide UFSAR Section Alternative operators methods to locate 5.2.5 justified, and quantify RCS leakage and to perform a reactor coolant i inventory balance. Alarm i requirement is met by l transmittal of alarm signals l provided by other systems to l the annunciator and computer i systems.
C.8 Yes. No Surveillance testing TSs 4.4.5.1, l exception requirements. 4.4.5.2.1 and i
t 4.4.5.2.2
, C.9 Yes. No TechnicalSpecifications(TS) TSs 3.4.5.1 and l exception, in compliance with RG 1.45. 3.4.5.2 j Page 7 of 7 l
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