ML20236S615

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Forwards Suppl 2 to Applications for Amends to Licenses NPF-10 & NPF-15,revising TS 3.8.1 to Extend Offsite Circuit Completion Time from 72 Hr & 6 Days from Discovery of Failure to Meet LCO
ML20236S615
Person / Time
Site: San Onofre  
Issue date: 07/22/1998
From: Nunn D
SOUTHERN CALIFORNIA EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20236S617 List:
References
NUDOCS 9807270107
Download: ML20236S615 (3)


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EDISON S"2P An LDISON INTLRAATIOAAL" Company July 22, 1998 i

U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C.

20555 Gentlemen:

l 1

Subject:

Docket Nos. 50-361 and 50-362 Amendment Application Nos. 150 and 134, Supplement 2

'i Extension of Emergency Diesel Generator Completion Time San Onofre Nuclear Generating Station Units 2 and 3

References:

1.

November 2,1995 letter from Richard M. Rosenblum (SCE) to I

Document Control Desk (NRC),

Subject:

Amendment Application Nos.150 and 134, Extension of Emergency Diesel Generator Allowed Outage Time, San Onofre Nuclear Generating Station, Units 2 and 3 i

2.

January 9, 1998 letter from Dwight'E. Nunn (SCE) to Document Control Desk (NRC),

Subject:

Amendment Application Nos. 150 and 134, Supplement 1, Extension of Emergency Diesel Generator Completion Time, San Onofre Nuclear Generating Station, Units 2 and 3 l

1 3.

CE0G CE NPSD-996, " Joint Applications for Emergency Diesel

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Generators A0T Extension," May 1995 4.

Letter dated June 19, 1998, from James W. Clifford (NRC) to Harold B. Ray (SCE),

Subject:

Issuance of Amendment for San Onofre Nuclear Generatin Ms. M94934 and M94936) g Station, Unit No. 2 (TACand Unit No. 3 (TA M94937) is Supplement 2 to Amendment Application Nos.150 and 134 to facility Operating Licenses NPF-10 and NPF-15 for the San Onofre Nuclear l0 Generating Station (SONGS) Units 2 and 3, respectively. Supplement 2 to these amendment applications supersedes entirely the applications forwarded by the References 1 and 2, which are hereby withdrawn.

These amendment applications consist of Proposed Change Number (PCN)-453, Supplement 2.

l The original PCN-453, submitted by Reference 1 and supplemented by Reference 2, was a request to modify Technical Specification (TS) 3.8.1 to axtend the proposed Offsite Circuit Completion Time from "72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> MQ 6 days I

from discovery of failure to meet LC0" to "72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> MQ 17 days from discovery, A,{),.)l of failure to meet LC0".

Also, the Completion Time for the Emergency Diesel

P Generator (EDG) was requested to be extended from "72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> MQ 6 days from discovery of failure to meet LC0" to "14 days MD 17 days from discovery of failure to meet LCO."

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Fax 949 368-1490 ADOCK 05000361 l l

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Document Control Desk p, The main purpose'for submitting PCN 453, Supplement 2 is to make a change to

.the basis for approval of the license amendment request.

Reference 2 provided E

Probabilistic Risk Analysis data in support of the proposed extensions to the Completion Times for TS 3.8.1.

This data took credit for the installation of l

an Inter-Unit EDG Cross-Tie. Because this Cross-Tie is not part of the design i

basis of Units 2 and 3, Southern California Edison (SCE) has determined that the Cross-Tie should not be included as part of the basis for acceptability of i

this license amendment request. The DG Cross-Tie and the extended Completion L

Time for the EDG will be treated as a separate issue.

PCN 453, Supplement 2, l

1s consistent with the presentation made to the NRC staff on July 10, 1998.

i

.This. license amendment application is based on a collaborative effort by participating Combustion Engineering Owners Group (CE0G) members based on an iategrated review and assessment of plant operations, deterministic and design i

basis considerations, and plant risk.~ Reference 3, which was submitted to the l

NRC staff for review and approval under separate cover, provides the basis for the methodology used in an augmented analysis to assess the impact of extending the current EDG Completion Time to 14 days in support of this proposed change. The additional information in Enclosure 2 supplements Reference 3.

Supplement I to PN 453 included a request to add a new TS 5.5.2.14

" Configuration Ri n Management-Program." The main purpose of the L

Configuration Risk Management Program (CRMP) is to ensure that a L

procedura11 zed Probabilistic Risk. Assessment-informed process is in place that i

assesses the overall impact of plant maintenance on plant risk.

Implementation of the CRMP enables appropriate actions to be taker, or

. decisions to be made to minimize and control risk when )erforming on-line

. maintenance for Systems. Structures, and Components wit1 a risk-informed Completion - Time. TS 5.5.2.14 is applicable to TS 3.8.1 because the Completion l-Times for TS 3.8.1 are " risk-informed Completion Times."

Because TS 5.5.2.14, " Configuration Risk Management Program (CRMP)," was recently incorporated into the TSs, by Reference 4 the request to add proposed TS 5.5.2.14 is not included in PCN 453, Supplement 2.

This is the l

~only change to the proposed TSs submitted by Reference 2.

Consistent with the presentation made to the NRC staff on July 10, 1998, SCE requests approval of this license amendment request by September 1, 1988, to permit on-line maintenance of a Unit 2 EDG in December of 1998.

SCE requests that this amendment be issued effective as of its date of issuance and be implemented within 30 days from the date of issuance.

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, Document Control Desk-If you would like additional information on this Technical Specification change request, please let me know.

Sincerely, C-1

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I Enclosures cc:

E. W. Merschoff,. Regional Administrator, NRC Region IV K. E. Perkins, Jr., Director, Walnut Creek ~ Field Office, NRC Region IV J. A. Sloan, NRC Senior Resident Inspector, San Onofre Units 2 & 3 J. W. Clifford, NRC Project Manager, San Onofre Units 2 and 3 S. Y. Hsu, Department of Health Services, Radiologic Health Branch I

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