ML20202H422
| ML20202H422 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 12/05/1997 |
| From: | Rainsberry J SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| IEIN-97-008, IEIN-97-8, NUDOCS 9712100278 | |
| Download: ML20202H422 (2) | |
Text
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' c p mm-mom-d EDISON L';f,flCu_.,
an spwv nwn mow comen, December 5, 1997 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555 Gentlemen:
Subject:
Docket Nos. 50-361 and 50-362 Request for Technical Specification Interpretation San Onofre Nuclear Generating Station Units 2 and 3 This letter requests on interpretation os Technical Specification 3.8.1 Action B.2 in accordance with Information Notice 97-80, " Licensee Technical Specifications Interpretations." Action B.2 states: " Declare required feature (s) supported by the inoperable DG inoperable when its redundant requiredfeature(s)isinoperable."
As indicated in the Basis to Technical Specification 3.8.1, " Required Action B.2 is intended to provide assurance that a loss of offsite power, during the period that a 06 is inoperable, does not result in a complete loss of safety function of critical systems.
These features are designed with redundant trains. This includes motor driven auxiliary feedwater pumps.
Single train systems, such as turbine driven auxiliary feedwater pumps, are not included.
Redundant required feature failures consist of inoperable features associated with a train, redundant to the train that has an inoperable DG."
However, the specific features covered by this Action are not specifically identified in the San Onofre Tea.hnical Specifications or Bases. An NRC interpretation of the applicable features covered by this Action is requested.
It is SCE's understanding that the specific features to which this Action applier are those " critical features" that require 1E pown from one of the 4 kV buses (A04 or B04 at San Onofre Units 2 and 3) to perform their safety function in the event of a loss of offs;t.e power.
Systems that fail in their safe position on loss of power, do not require power, or whose failure does not result in a " complete loss of safety function" are not included.
In addition, instrumentation that is' powered from a battery backed source (e.g., the vital buses) is also not included. This instrume.itation would not suffer a " complete loss of safety function" in the event of a loss of offsite l
power because of the battery backup power.
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P. O.Ikn 128
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San Clemente CA 92674-01M '
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1 L 9712100279 971205
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i Document Control Desk,
Based on this understanding, SCE currently includes the following systems
-withinthescopeofActionB.2_(theassociatedTechnica1' Specifications-(TS) arelistedinparentheses): boration systems (TS 3.1.9), emergency core coolingsystems(TS3.5.2),containmentsprayandcoolingsystems (TS3.6.6.1),containmentdomeaircirculators(TS3.6.8),auxiliaryfeedwater system (TS3.7.5),componentcoolingwatersystem(TS3.7.7), saltwater l
cooling system (TS 3.7.8), emergency chilled water (TS 3.7.10), control room emergency air cleanup system (TS 3.7.11), and fuel handling building post-accident-cleanupfiltersystem-(TS3.7.14).
l Following receipt of the NRC interpretation of this Action statement it is SCE's intention to incorporate this into the Bases for Technical Specification B.2.
l If you have any questions regarding this request,-please let me know.
Very truly ycurs, e
cc:
E. W. Herschoff, Regional Administrator, NRC Region IV K. E. Perkins, Jr., Director, Walnut Creek Field 0ffice, NRC Region IV J. A. Sloan NRC Senior Resident inspector, San Onofre Units 2 & 3 M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3
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