ML20207H402

Requests Addl Info Re Completion of Time for Containment Isolation Valves,Same as for Engineered Safeguards Features

ML20207H402
Person / Time
Site:	San Onofre
Issue date:	06/14/1999
From:	Raghavan L NRC (Affiliation Not Assigned)
To:	Ray H SOUTHERN CALIFORNIA EDISON CO.
References
TAC-MA1549, TAC-MA1550, NUDOCS 9906160263
Download: ML20207H402 (5)

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UNITED STATES l NUCLEAR REGULATORY COMMISSION U WASHINGTON, D.C. 30000 0001

• • • • • June 14,1999

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Mr. Harold B. Ray

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! Executive Vice President Southem California Edison Company San Onofre Nuclear Generating Station P. O. Box 128 San Clemente, CA 92674-0128 l

SUBJECT:

SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 -

REQUEST FOR ADDITIONAL INFORMATION CONTAINMENT ISOLATION j VALVE COMPLETION TIME TECHNICAL SPECIFICATION (TAC NOS. 1 l

MA1549/MA1550)

Dear Mr. Ray:

l i

in a letter dated April 6,1998, you submitted a request for amendment to the San Onofre Nuclear Generating Station (SONGS) Units 2 AND 3 technical specifications (TSs) to make the i

completion time for containment isolation valves (CIVs) the same as for the engineered safeguards features for the systems to which they are associated. In response to our request for additional information (RAI), by letter dated March 22,1999, you provided certain additional information. As a result of our review of your March 22,1999, response to our RAI, we have determined that we need certain additional information as discussed below.

1. Section C.2 of Regulatory Guide (RG) 1.177, "An Approach for Plant-Specific, Risk Informed Decisionmaking: Technical Specifications," describes the specific aspects of the engineering evaluation to be conducted h support of a proposed change to a plant's TSs. In particular, the engineering evaluation under RG 1.177 includes compliance with current regulations (Section 2.1), traditional engineering considerations (Section 2.2), and evaluation of risk impact (Section 2.3). The traditional engineering considerations in Section 2.2 include a determination of whether the impact of the proposed TS change is consistent with the defense-in-depth philosophy. RG 1.177 summarizes specific elements as guidance for assessing defense in depth. Your submittal does not address the impact on the defense-in-depth philosophy of the proposed TS change, e.g.,

(a) overall availability and reliability of the various affected safety systems with the l removal of numerous valves from service over the operating cycle, o l (b) maintenance of defenses against potential common-cause failures and its assessment of the potential for introduction of new common-cause failure / 0\ '

mechanisms, (c) potential degradation of the independence of physical barriers by the proposed TS change, and  ;

l (d) maintenance of defer ses against human errors such as those resulting from l use of different personnel or performece constraints during plant operation.

9906160263 990614 i PDR ADOCK 05000361 P PDR

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Lo - C June 14, 1999

' Harold B. Ray -2.- k

.. i Please provide your assessment and discussion how the proposed TS change meets the defense-in-depth principle, including your plans for implementing the proposed TS change.

2. Your March 22,1999 letter (Table 2) indicates that removal of charging valve HV-9200 I from service would result in the unavailability of the charging system. Please describe I your proposed use of an abnormal operating instruction to establish an attemate charging path and acceptability of that approach with respect to current TS and license commitments. _,

- 3. Please discuss how often you plan to use the proposed CIV completion time. To provide confidence in your risk evaluations and to provide for the possibility that you may use the proposed completion time more than once every six years, please provide  !

a sensitivity _ calculation to determine the change in the core damage f requency for each of the CIVs using your proposed completion time once a year, not just once every six years.

4. Please state whether the CIVs are in your proposal are covered by your Maintenance Rule program? What are the performance criteria for each of these valves? Please describe the appropriateness of these criteria.

5. With respect to your proposed on-line maintenance and testing of multiple components during power operation, please describe the methodology for taking out components from various ECCS such that the ECCS requirements for design basis accidents will be unaffected.

On April 14,1999, by facsimile we provided these questions, and on May 13,1999, discussed them with Jack Rainsberry et al of your staff. _ Your staff agreed to provide your responses to the above questions within 45 days of the date of this letter. If circumstances result in the need

. to revise the target date, please call me at the earliest oppor1 unity.

Sincerely ORIG. SIGNED BY L. Raghavan, Senior Project Manager, Section 2 e - , , Project Directorate IV & Decommissioning

• • uu00 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-361 and 50-362  :

y cc: See next page DISTRIBUTION:

meshetMel OGC SMalik KDesal PUBLIC ' -ACRS TScarbrough JPulsipher PDIV-2 Reading - , KBrockman, RIV L.Raghavan CJamerson dilhvelinski/SBlack LSmith, RIV Document Name: G:\PDIV-2\ SONGS \rala1549-2.wpd

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b DATE 640/99 6 /14 /9 9 [

6/10 /99 '6/10 /99 6/10/99 [ / f/ /99 M M *5 OFFICIAL RECORD COPY

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Harold B. Ray l Please provide your assessment and discussion how the proposed TS ch ge meets the defense-in-depth principle, including your plans for implementing t proposed TS change. j i

2. Your March 22,1999 letter (Table 2) indicates that removal of arging valve HV 9200 from service would result in the unavailability of the chargin ystem. Please describe your proposed use of an abnormal operating instruction tp stablish an altemate charging path and acceptability of that approach with r pect to current TS and license commitments.

3. Please discuss how often you plan to use the pr posed ClV completion time. To provide confidence in your risk evaluations a to provide for the possibility that you may use the proposed completion time mor than once every six years, please provide a sensitivity calculation to determine the ange in the core damage frequency for each of the CIVs using your proposed comp ion time once a year, not just once every six years.

4. Please state whether the CIVs a in your proposal are covered by your Maintenance Rule program? What are the rformance criteria for each of these valves? Please

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describe the appropriatenes of these criteria.

On April 14,1999, by facsimile e provided these questions, and on May 13,1999, discussed them with Jack Rainsberry et of your staff. Your staff agreed to provide your responses to the above questions within days of the date of this letter, if circumstances result in the need to revise the target date, ease call me at the earliest opportunity.

Sincerely L. Raghavan, Senior Project Manager, Section 2 Project Directorate IV & Decommissioning Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No . 50 361 and 50-362 cc: See ext page DIST UTION:

Doc t File OGC SMalik KDesal P LIC ACRS TScart/d4b JPulsipher P IV-2 Reading KBrockman, RIV L.Raghavan ,

CJamerson JZwolinski/SBlack LSmith, RIV l l

Document Name: C:\ Songs \ma1549\ revised ral OFC PDIV-2/PM PDIV-D/LA SRXB[Sc EMEB/sc SPSB, PDIV-2/SC NAME LRaghavan CJamerson #6 4A"/ V 'D he .

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DATE 5/ /99 5/ /99 6 //o/99 I //0/99 h10/99 5/ /99 OFFICIAL RECORD COPY l

I Harold B. Ray 1 Please provide your assessment and discussion how the proposed TS change meets the defense-in-depth principle, including your plans for implementing the proposed TS change.

2. Your March 22,1999 letter (Table 2) indicates that removal of charging valve HV 9200 from service would result in the unavailability of the chcrging system. Please describe ,

your proposed use of an abnormal operating instnJction to establish an attemate charging path and acceptability of that approach with respect to current TS and license commitments.

3. Please discuss how often you plan to use the proposed CIV completion time. To provide confidence in your risk evaluations and to provide for the possibility that you may use the proposed completion time more than once every six years, please provide a sensitivity calculation to determine the change in the core damage frequency for each of the CIVs using your proposed completion time once a year, not just once every six years.

4. Please state whether the CIVs in your proposal are covered by your Maintenance Rule program? What are the performance criteria for each of these valves? Please describe j the appropriateness of these criteria.

5. With respect to your proposed on-line maintenance and testing of multiple components during power operation, please describe the methodology for taking out components ,

from various ECCS such that the ECCS requirements for design basis accidents will be  !

unaffected.

On April 14,1999, by facsimile we provided these questions, and on May 13,1999, discussed them with Jack Rainsberry of your licensing staff who agreed to provide responses to the above questions within 45 days of the date of this letter, if circumstances result in the need to revise the target date, please call me at the earliest opportunity.

Sincerely i

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L.Raghavan, enior Project Manager, Section 2 Project Directorate IV & Decommissioning Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50 361 and 50-362 cc: See next page

f l L San Onofre Nuclear Generating Station, Units 2 and 3 cc: ,

i Mr. R. W. Krieger, Vice President Mayor Southem Califomia Edison Company City of San Clemente San Onofre Nuclear Generating Station 100 Avenida Presidio P. O. Box 128 San Clemente, CA 92672 San Clemente, CA 92674-0128 Mr. Dwight E. Nunn, Vice President

' Chairman, Board of Supervisors Southem Califomia Edison Company 4 County of San Diego San Onofre Nuclear Generating Station 1 1600 Pacific Highway, Room 335 P.O. Box 128 San Diego, CA 92101 San Clemente, CA 92674-0128 Alan R. Watts, Esq.

Woodruff, Spradlin & Smart 701 S. Parker St. No. 7000 Orar, Ja, CA 92668-4720-Mr. Sherwin Harris - l Resource Project Manager-Public Utilities, Department City of Riverside 3900 Main Street Riverside, CA 92522 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission Harris Tower & Pavilion 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Mr. Michael Olson  ;

San Onofre Liaison j San Diego Gas & Electric Company P.O. Box 1831 San Diego, CA 92112-4150

' Mr. Steve Hsu

' Radiologic Health Branch .

State Department of Health Services Post Office Box 942732 Sacramento, CA 94234 Resident inspector / San Onofre NPS c/o U.S. Nuclear Regulatory Commission Post Office Box 4329 San Clemer.te, CA 92674 June 1999

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