ML080580474

San Onofre, Unit 3, Response to NRC Request for Additional Information in Support of Amendment Application No. 236, Proposed Change Number (Pcn) 582 Technical Specification (TS) 5.5.2.15 Containment Leakage Rate Testing Program

ML080580474
Person / Time
Site:	San Onofre
Issue date:	02/22/2008
From:	Scherer A E Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MD6835
Download: ML080580474 (31)

Text

J SOUTHERN CALIFORNIA EDISONAn EDISON INTERNATIONAL Company A. Edward Scherer Director Nuclear Regulatory Affairs February 22, 2008 U.S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, D.C. 20555

Reference:

Docket No. 50-362 Response to NRC Request for Additional Information in support of Amendment Application No. 236, Proposed Change Number (PCN) 582 Technical Specification (TS) 5.5.2.15 Containment Leakage Rate Testing Program, San Onofre Nuclear Generating Station, Unit 3 Letter from N. Kalyanam (NRC) to Richard M. Rosenblum (SCE) dated January, 16, 2008;

Subject:

San Onofre Nuclear Generating Station, Unit 3 -Request for Additional Information on License Amendment Request for One-Time Extension from the Currently Approved 15-year Interval Extension Since the Last Integrated Leak Rate Test (TAC No. MD6835)

Dear Sir or Madam:

By letter dated January 16, 2008 (Referenced above), the U.S. Nuclear Regulatory Commission issued a request for additional information regarding Proposed Change Number (PCN) 582. Please find the Southern California Edison (SCE) responses enclosed.SCE has evaluated the supplemental information under the standards set forth in 10 CFR 50.92 (c) and determined that SCE's original finding of "No significant hazards consideration" is not changed.There are no commitments contained in either this letter or the enclosure.

Abc-P.O. Box 128 San Clemente, CA 92674 Document Control Desk-2-February 22, 2008 If you have any questions or require additional information, please contact Ms. Linda T.Conklin at (949) 368-9443.Sincerely,

Enclosure:

As stated cc: E. E. Collins, Regional Administrator, NRC Region IV N. Kalyanam, NRC Project Manager, San Onofre Units 2 and 3 C. C. Osterholtz, NRC Senior Resident Inspector, San Onofre Units 2 and 3 S. Y. Hsu, California Department of Public Health, Radiological Health Branch Southern California Edison (SCE)San Onofre Nuclear Generating Station (SONGS), Units 2 and 3 Docket No. 50-362 Enclosure Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 582 Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 582 NRC Question 1: The request for a one-time extension from the currently approved 15-year Integrated Leak Rate Test (ILRT) interval to a 16-year ILRT interval is based on a later version of the San Onofre Nuclear Generating Station, Unit 3 (SONGS 3)probabilistic risk analysis (PRA) and offsite consequence analysis used to support the 15-year extension (as provided in Southern California Edison's May 27, 2005, letter Agencywide Documents Access and Management System (ADAMS) ML051530089).

Please provide a description of: a. the major changes to the Level 1 PRA that resulted in the increase in internal events core damage frequency from 1.79E-5 per year to 3.OOE-5 per year, b. the major changes to the Level 2 PRA and/or offsite consequence analysis that resulted in the reduction in the baseline offsite population dose from 35.5 to 9.7 person-roentgen equivalent man (rem) per year for internal events, and from 72.9 to 12.2 person-rem per year for internal and external events combined, and c. the internal and external reviews of the above changes, and the findings and recommendations from these reviews.SCE Response to I a. the major changes to the Level 1 PRA that resulted in the increase in internal events core damage frequency from 1.79E-5 per year to 3.OOE-5 per year, The reason for the increase in the core damage frequency (CDF) value is the PRA model and data changes made to support the resolution of the peer review facts and observations (F&Os) and also to keep the PRA model up to date. These changes were made in the period of 2004 to 2006 with most of the changes being made in 2005 and 2006 between the two ILRT interval extension requests.

A relatively large number of F&Os resulted from the SONGS 2 and 3 PRA peer review against the ASME PRA standard.

All F&Os regardless of their significance level (i.e., A, B, C, or D comments)were resolved.

This resulted in a number of PRA model and data changes, which consequently resulted in an increase in the baseline internal events CDF value. The resolution of the peer review F&Os are documented in the PRA report IPE-CERT-003 (Reference 1). Examples of the major PRA model and data changes contributing to the CDF increase are as follows: Page 1 of 12 Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 582 A systematic identification, grouping, and quantification of potential initiating events (lEs) resulted in adding several new lEs to the SONGS 2 and 3 PRA. Particularly, a number of loss of support systems as lEs were added to the model. Examples of the new IEs are:* Loss of instrument air or inadvertent containment isolation actuation signal (CIAS)* Loss of component cooling water (CCW) non-critical loop (NCL)* Loss of 4.16 Kv buses* Loss of condenser heat sink 2. Several initiating event frequency estimates were increased due to periodic updates (such as loss of offsite power, very small loss of coolant accident (LOCA)) or addition of new failure contributors.

For example, small LOCA initiating event frequency was increased because reactor coolant pump (RCP)seal failure and stuck open safety valve contributions were added to the originally modeled pipe failures.

As an additional example, the main steam line break initiating event frequency went up due to addition of main steam isolation valve (MSIV) failures, atmospheric dump valve (ADV) failures, or main steam supply valve (MSSV) failures to pipe failures.3. The addition of several components to the system fault trees contributed to higher system failure probabilities.

For example, two new basic events were added for two valves (i.e., the manual valve between the two condensate storage tanks, and the air-operated steam supply valve for the steam-driven pump) in the auxiliary feedwater system (AFWS), which contributed to higher system unavailability as well as a higher CDF value.4. The addition of new common cause failure (CCF) basic events for several components such as inverters, buses, fans, filters, and strainers contributed to higher system unavailabilities as well as a higher CDF value.5. The update of the component average unavailabilities resulted in higher values, which consequently increased the CDF value.6. The revision of the recovery factor value used for the periodic checks (e.g., daily or monthly) in modeling the pre-initiating event human errors resulted in higher human error probability (HEP) estimates for the affected human failure events, which consequently increased the CDF value.Page 2 of 12 Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 582 SCE Response to 1 b. the major changes to the Level 2 PRA and/or offsite consequence analysis that resulted in the reduction in the baseline offsite population dose from 35.5 to 9.7 person-roentgen equivalent man (rem) per year for internal events, and from 72.9 to 12.2 person-rem per year for internal and external events combined, and No major changes were made to the Level 2 probabilistic risk assessment (PRA) as a result of peer review F&O resolutions or PRA model/data updates. However, different dose estimates were used in the two integrated leak rate test (ILRT) interval extension requests in 2005 (Reference

11) and 2007 (Reference

12) and the frequency of the release categories was altered as a result of the changes in the Level 1 PRA, as explained below.As a part of the submittal for extension of the ILRT testing interval it is necessary to obtain the baseline dose estimate.

Two sources are utilized to define the dose estimates and are split between the EPRI classes identified in Reference

2. Classes 2, 4 and 5 are not addressed by the analysis since they are not impacted by the requested testing interval extension consistent with the methodology.

The development and variations between the earlier submittal and the current submittal are discussed individually and then the overall impact is summarized.

EPRI Classes 1, 3a and 3b The dose estimates for the intact containment (Class 1) and the impaired cases (Classes 3a and 3b) as a result of unidentified containment leakage are based on the design basis dose assessment.

For the 15-year extension assessment documented in RSC 04-02 (Reference 3, PCN 554, 2004) and the subsequent response to RAIs documented in RSC 05-03 (Reference 4, PCN 554, 2005), the intact dose was based on the licensing basis analysis (Reference

5) and a total dose of 222 person-rem was generated (refer to RSC 05-03, Appendix B for development).

During the time between the 15-year submittal and the 16-year submittal SONGS implemented the AST source term results. Therefore, for the 16-year extension assessment documented in RSC 07-05 (Reference 6, PCN 582, 2007), the adopted AST source term assessment is utilized for the analysis (Reference 7). The use of this information reduced the dose estimate to 170 person-rem (refer to RSC 07-05, Appendix B for development).

The impact of this change on the dose estimates is provided in Table 1 below (for internal events). Similar comparisons can be made for the internal and external events analysis.Page 3 of 12 Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 582 Table 1 Comparison of Annual Dose for the 16-year and the 15-year Extension Analyses for Classes 1, 3a and 3b (for Internal Events Analysis)EPRI Class 16-year Analysis 15-year Analysis % Change (RSC 07-05, Table 6) (RSC 05-03, Table 6) in P-Rem/yr Frequency/yr P-Rem P-Rem/yr Frequency/yr P-Rem P-Rem/yr Class 1 2.36E-05 1.70E+02 4.013E-03 1.45E-05 2.22E+02 3.210E-03 25%Class 3a 8.25E-07 1.70E+03 1.404E-03 4.93E-07 2.22E+03 1.095E-03 28%Class 3b 8.21E-08 5.95E+03 4.887E-04 4.91E-08 7.77E+03 3.811E-04 28%Total 5.91 E-03 4.69E-03 26%The 16-year extension results are approximately 26% higher than those presented in the 15-year assessment.

Although the source term is reduced for the 16-year case, a more pronounced increase in accident sequence frequency offsets this reduction such that overall the results are higher than for the prior analysis and is responsible for the major difference in the results.EPRI Classes 6, 7 and 8 For the impaired containment cases (Classes 6, 7, and 8) involving other release paths, such as bypass failures or phenomena-induced, the dose is estimated utilizing the results of the SONGS Level 2 PRA.To obtain the dose estimates for Classes 6, 7, and 8 the original submittal assessment (RSC 04-02, Reference

3) utilized a consultant-developed methodology (Reference 8)for the estimation of dose given specific radionuclide release fraction identified from the SONGS Level 2 PRA and this analysis was documented in that report as Appendix B (refer to Appendix B of Reference 3, PCN 554, 2004) and was based on a method utilized in previously approved submittals (Reference 9).Subsequent to the submittal of this analysis and in response to the request for additional information during the NRC staff review of that analysis, the NRC staff presented a request to apply a generic assessment methodology similar to that being utilized for the industry SAMA process that was based on the extrapolation of the dose results found in NUREG-1 150 (surrogate approach).

There was also a request to provide an alternative assessment utilizing the NEI methodology (Reference

10) to assess the change in risk associated with the proposed ILRT extension.

Page 4 of 12 Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 582 The responses to both of these requests were documented as report RSC 05-03 (Reference 4). The report exercised the NEI methodology utilizing the consultant-developed dose method in the main report and a comparison of those results to the results obtained using the surrogate approach was documented in Appendix B, Section B.3.For the recently submitted request to extend the testing to 16 years, the analysis documented in RSC 07-05 (Reference

6) utilized the NEI methodology and did not apply the consultant-developed approach for dose estimation but instead utilized the surrogate approach in consideration of prior RAIs generated during the NRC staff review of the submittal extending the testing interval to 15 years.As a result of this change, the main document dose estimates for Classes 6, 7 and 8 are not directly comparable to the earlier submittal and are in fact smaller than would have been predicted by the consultant-developed method. A comparison of the estimated doses generated by the consultant-developed method and the surrogate method is presented in Table 2 below (from RSC 05-03 (Reference 4), Appendix B, Table B.8) for the Classes where it was applied.Table 2 Comparison of Surrogate and Consultant Methods for Dose Exposure for the 15-year Case (Table B.8 in RSC 05-03 (Reference 4))EPRI Class Surrogate Consultant Exposure Ratio (person-rem) (person-rem)

Class 6 2.06E+6 2.93E+6 1.42 Class 7 1.62E+6 7.80E+6 4.81 Class 8 2.14E+6 3.07E+7 14.35 The consultant-based value is higher for all classes with the largest difference being associated with EPRI Class 8 (bypass failures).

This difference has a significant impact on the total dose. For the sensitivity study presented in RSC 05-03 (Reference 4), the consultant-developed method yielded a baseline person-rem for the baseline internal events analysis of 35.5 person-rem.

The surrogate method yielded a reduced value of 5.2 person-rem (from Appendix B, Table B.9 in RSC 05-03 (Reference 4). Since the report evaluating the extension to 16 years utilizes the surrogate methodology, the 5.2 person-rem value should be used for comparisons between the prior submittal and the new extension analysis.Page 5 of 12 Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 582 The dose estimate is a combination of the dose value and the frequency of the class. A breakdown of this information for both the prior 15 year extension and the 16 year extension is presented in Table 3 below (for internal events). Similar comparisons can be made for the internal and external events analysis.Table 3 Comparison of Dose for the 16-year and the 15-year Extension Analyses (for Internal Events Analysis)EPRI 16-year Analysis 15-year Analysis %Class (RSC 07-05, Table 9) (RSC 05-03 Sensitivity using Table 8 for Change in Frequencies and Table B.8,for P-Rem/yr Surrogate person-rem)

Frequency/yr P-Rem P-Rem/yr Frequency/yr P-Rem P-Rem/yr Class 6 3.26E-07 2.06E+06 6.699E-01 1.56E-07 2.06E+06 3.214E-01 108%Class 7 4.15E-06 1.62E+06 6.727E+00 2.22E-06 1.62E+06 3.601E+00 87%Class 8 1.07E-06 2.14E+06 2.283E+00 5.75E-07 2.14E+06 1.230E+00 86%Total 9.68E+00 5.15E+00 88%The information contained in the table indicate that change in dose from the prior analysis utilizing the same dose methodology can be linked directly to the increases in core damage frequency as they propagate through the Level 2 analysis.Summary and Expansion to External Events The comparison of like-methodology developed estimates for dose strongly indicate that the controlling factor in the difference in dose estimate is the increase in the core damage frequency for SONGS as it is propagated through the Level 2 analysis.

The consequential person-rem estimates for each class are essentially unchanged for the 15-year and 16-year cases with the implementation of the AST resulting in a small decrease for the Class 1, 3a and 3b cases. However, this change has an insignificant impact on the total dose estimates due to the relatively small contribution of these classes to the total dose.Page 6 of 12 Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 582 SCE Response to 1 c. the internal and external reviews of the above changes, and the findings and recommendations from these reviews: The PRA peer review F&Os were resolved with the assistance of two outside contractors (Scientech, LLC, and Maracor Software & Engineering, Inc.), and the resolutions were reviewed internally by the PRA staff and also by another outside contractor (ERIN Research & Engineering, Inc.), who was not involved in the F&O resolution task. Those F&Os that were resolved internally by the PRA staff were also reviewed by ERIN. Both editorial and technical recommendations and comments received from internal and external reviews were resolved as documented in the PRA report IPE-CERT-003 (Reference 1). ERIN concluded that each of the F&Os was addressed and that the approaches taken for resolving the F&Os were consistent with industry practices.

The dose calculations in support of the 15-year submittal (RSC 05-03, Reference

4) and the 16-year submittal (RSC 07-05, Reference

6) were reviewed internally by the staff of Ricky Summitt Consulting, Inc. as well as externally by SCE staff. The internal and external reviewers agreed that the surrogate approach (NUREG-1 150) was appropriate for this application.

Both editorial and technical comments received from internal and external reviewers were resolved.

The 15-year submittal (PCN 554, Reference

11) and the 16-year submittal (PCN 582, Reference

12) reflect the final comment resolution.

NRC Question 2: The baseline risk assessment indicates that the increase in large early release frequency (LERF) resulting from a change in the ILRT interval from three tests in 10 years to one test in 16 years is 5.27E-7 per year (for internal and external events combined).

This value was subsequently reduced to 8.69E-8 per year through three successive refinements in the analysis that credited: (a) removal of sequences with operation of containment sprays or flooding of ex-vessel core debris, (b) more realistic treatment of the probability of sump clogging, and (c)removal of additional sequences in which key fission products would not be released in an early timeframe.

The total LERF for San Onofre is not reported in the submittal.

Provide the total LERF (for internal events as well as internal and external events combined) for the baseline analysis and for each of the three refined analyses.SCE Response to Question 2: For the proposed 16-year ILRT interval, the increase in large early release frequency (LERF) relative to the 3 tests in 10 years ILRT and the total LERF for internal events for the unadjusted baseline analysis and three refined analyses (i.e., cases (a), (b), and (c)in the question above) are provided in Table 4 below. Similar results for the internal and external events combined are provided in Table 5 below. All the referenced tables are those provided in Enclosure 3 of the ILRT interval extension request submittal (Reference 12). The calculation of Type A LERF (Class 3b) estimates for the three Page 7 of 12 Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 582 refined cases are repeated in Tables 4 and 5 below. As noted in the submittal (Reference 12), the tables and illustrational calculation steps presented in the submittal reported rounded values to support readability.

The detailed calculations performed to support the analysis were of a level of mathematical significance necessary to calculate the results recorded.

This also applies to Tables 4 and 5 below. It is observed that the largest total LERF for the baseline analysis (or unadjusted case) for the internal and external events combined is 1.34E-6/yr, which is below the 1.OE-5/yr total LERF criterion in the Regulatory Guide 1.174.Page 8 of 12 Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 582 Delta LERF (Relative to 3 Tests in for Baseline 1 Analysis and Three Table 4 10 Years ILRT) and Total LERF for Internal Events Refined Analyses for the Proposed 16-Year ILRT Interval Case PRA Original LERFW Delta LERF (/yr) Total LERF 4 =(/yr) (Increase in Type A LERF)3 PRA LERF +Type A LERF (/yr)Baseline 5.59E-7 (Table 11) 4.38E-7 (Table 10) -8.21E-8 (Table 5.59E-7 +(or unadjusted)

10) = 3.56E-7 4.38E-7 =9.97E-7[3.00E-5 (total CDF) *0.00273 * (96/18) = 4.38E-7] -[8.21E-8]

= 3.56E-7 Refinement (a) 5.59E-7 (Table 11) 2.70E-7 (Table 12) -5.07E-8 (Table 5.59E-7 +12) = 2.19E-7 2.70E-7 =8.29E-7[1.85E-5 (adj. CDF or STC4) *0.00273 * (96/18) = 2.70E-7] -[5.07E-8]

= 2.19E-7 Refinement (b) 5.59E-7 (Table 11) 2.34E-7 (Table 14) -4.38E-8 (Table 5.59E-7 +14) = 1.90E-7 2.34E-7 =7.93E-7[(1.85E-5

-2.51 E-6 (SLE-11 adj, Table 13)) =1.6E-5 *0.00273 * (96/18) = 2.34E-7] -[4.38E-8]

= 1.90E-7 Refinement (c) 5.59E-7 (Table 11) 9.05E-8 (Table 18) -1.70E-8 (Table 5.59E-7 +18) = 7.35E-8 9.05E-8 =6.50E-7[(1.6E-5 -5.06E-6 (PCS35, Table 17) -4.78E-6 (MLO4, Table 17)) = 6.21E-6 *0.00273 * (96/18) = 9.05E-8] -[1.70E-8]

= 7.35E-8 1 Baseline here refers to the unadjusted case (i.e., no refinement to Type A LERF). The term "Baseline" is also referred to in the 3-year ILRT interval case in the submittal (Reference 12).2 This represents the "original" LERF as calculated in the PRA, representing sequences for SGTR, ISLOCA, containment isolation failures, and early containment failures.

This is not adjusted in the ILRT interval extension analysis.3 The values in this column represent the delta LERF for the 16-year ILRT interval relative to the 3 tests in 10 years ILRT. Conservatively treated as LERF per NEI guidance for the purpose of ILRT interval extension, these values represent only the increase in the Class 3b frequency (Type A containment leakage) due to the ILRT interval extension.

This delta LERF is calculated based on the potential that intact containment sequences in the PRA could be impaired by an unknown leakage in the containment (so called Class 3b). This would shift some intact containment sequences (which were not LERF of course) to LERF. This is the only change in LERF addressed in this assessment.

These values are compared with the total delta LERF acceptance criterion of 1.OE-7/yr in Regulatory Guide 1.174.4 The total LERF is the sum of the PRA original LERF, which is unaffected by this change, and the Type A LERF (Class 3b) for the proposed 16-year ILRT interval.

These values are compared with the total LERF acceptance criterion of 1.OE-5/yr in Regulatory Guide 1.174.Page 9 of 12 Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 582 Table 5 Delta LERF (Relative to 3 Tests in 10 Years ILRT) and Total LERF for Internal and External Events for Baseline 1 Analysis and Three Refined Analyses for the Proposed 16-Year ILRT Interval Case PRA Original Delta LERF (lyr) Total LERF 4 =LERF 2 (/yr) (Increase in Type A LERF)3 PRA LERF +Type A LERF (/yr)Baseline 6.96E-7 (Table A.11) 6.48E-7 (Table A.10) -1.21E-7 (Table A.10) 6.96E-7 +(or unadjusted)

= 5.27E-7 6.48E-7 =1.34E-6[4.44E-5 (total CDF) *0.00273 * (96/18) = 6.48E-7] -[1.21 E-7] =5.27E-7 Refinement (a) 6.96E-7 (Table A. 11) 3.04E-7 (Table A.12) -5.69E-8 (Table A.12) 6.96E-7 += 2.47E-7 3.04E-7 =1.OOE-6[2.08E-5 (adj. CDF or STC4) *0.00273 * (96/18) = 3.04E-7] -[5.69E-8]

=2.47E-7 Refinement (b) 6.96E-7 (Table A. 11) 2.67E-7 (Table A. 13) -5.OOE-8 (Table A. 13) 6.96E-7 += 2.17E-7 2.67E-7 =9.63E'-7[(2.08E-5

-2.51 E-6 (SLE-1 1 adj, Table 13)) =1.83E-5 *0.00273 * (96/18) = 2.67E-7] -[5.00E-8]

=2.17E-7 Refinement (c) 6.96E-7 (Table A. 11) 1.07E-7 (Table A. 16) -2.01 E-8 (Table A. 16) 6.96E-7 += 8.69E-8 1.07E-7 =8.03E-7[(1.83E-5

-5.06E-6 (PCS35 Internal, Table 17) -1.29E-7 (PCS35 External, Table A.14) -4.78E-6 (MLO4 Internal, Table 17) -1.01 E-6 (MLO4 External, Table A.14)) =7.34E-6 *0.00273 * (96/18) = 1.07E-7] -[2.01 E-8] =8.69E-8 1 Baseline here refers to the unadjusted case (i.e., no refinement to Type A LERF). The term "Baseline" is also referred to in the 3-year ILRT interval case in the submittal (Reference 12).2 This represents the "original" LERF as calculated in the PRA, representing sequences for SGTR, ISLOCA, containment isolation failures, and early containment failures.

This is not adjusted in the ILRT interval extension analysis.3 The values in this column represent the delta LERF for the 16-year ILRT interval relative to the 3 tests in 10 years ILRT. Conservatively treated as LERF per NEI guidance for the purpose of ILRT interval extension, these values represent only the increase in the Class 3b frequency (Type A containment leakage) due to the ILRT interval extension.

This delta LERF is calculated based on the potential that intact containment sequences in the PRA could be impaired by an unknown leakage in the containment (so called Class 3b). This would shift some intact containment sequences (which were not LERF of course) to LERF. This is the only change in LERF addressed in this assessment.

These values are compared with the total delta LERF acceptance criterion of 1.OE-7/yr in Regulatory Guide 1.174.4 The total LERF is the sum of the PRA original LERF, which is unaffected by this change, and the Type A LERF (Class 3b) for the proposed 16-year ILRT interval.

These values are compared with the total LERF acceptance criterion of 1.OE-5/yr in Regulatory Guide 1.174.Page 10 of 12 Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 582

References:

1. IPE-CERT-003, Peer Review F&O Resolutions and Capability Category Assessment Report, Southern California Edison 2. Gisclon, J. M., et al, Risk Impact Assessment of Revised Containment Leak Rate Testing Intervals, Electric Power Research Institute, TR-104285, August 1994 3. Miller, J., San Onofre Nuclear Generating Station Probabilistic Risk Assessment Evaluation of Risk Significance of ILRT Extension, Revision 0, Ricky Summitt Consulting (RSC), Inc., RSC 04-02, March 2004 4. Summitt, R., San Onofre Nuclear Generating Station Probabilistic Risk Assessment Evaluation of Risk Significance of ILRT Extension Based on the NEI Approach, Rev 0., RSC, Inc., RSC 05-03, April 2005 5. Arastu, A., Calculation N-4061-002, Post-LOCA Containment Leakage-CR

&Offsite Doses, Southern California Edison, Revision 0, August 2000 6. Summitt, R, San Onofre Nuclear Generating Station Unit 3 Probabilistic Safety Assessment Evaluation of Risk Significance of ILRT Extension Based on the NEI Approach, Rev 0., RSC, Inc., RSC 07-05, July 2007 7. Schulz, J., Calculation N-6060-002, LOCA Containment Leakage, CR & Offsite Doses -AST, Southern California Edison, Revision 0, November 2003 8. Summitt, R., Surrogate Level 3 Evaluation Methodology, Rev 0., RSC, Inc., RSC 01-44, August 2001 9. Summitt, R., Comanche Peak Steam Electric Station Probabilistic Safety Assessment, Evaluation of Risk Significance of ILRT Extension, RSC, Inc., RSC 01-47/R&R-PN-1 10, November 2001 10. Haugh, J., et al, Interim Guidance for Performing Risk Impact Assessments in Support of One-Time Extensions for Containment Integrated Leakage Rate Test Surveillance Intervals, Revision 4, Nuclear Energy Institute (NEI), November 2001 11. Letter from B. Katz (SCE) to the United States Nuclear Regulatory Commission (Document Control Desk) dated May 27, 2005;

Subject:

Docket Nos. 50-381 and 50-362, Supplement One To Amendment Application Nos. 224 and 208 Proposed Change Number (PCN) 554 Technical Specification (TS) 5.5.2.15 Containment Leakage Rate Testing Program San Onofre Nuclear Generating Station Units 2 and 3 Page 11 of 12 Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 582 References (Continued):

12. Letter from B. Katz (SCE) to the United States Nuclear Regulatory Commission (Document Control Desk) dated September 24, 2007;

Subject:

Docket No. 50-362, Amendment Application No. 236, Proposed Change Number (PCN) 582, Technical Specification (TS) 5.5.2.15, Containment Leakage Rate Testing Program. San Onofre Nuclear Generating Station Unit 3 Page 12 of 12 KIMBERLY K A : MENDICELLIISONGS/SCE/EI X 02/22/2008 10:26 AM To ALLISON SPOLERICH/SONGS/SCE/EIX@SCE, DARLA WADEISONGS/SCE/EIX@SCE, farrelda@songs.sce.com, Helen K Watkins/SCE/EIX@SCE, KIM cc A. E. SCHERER/SONGS/SCE/EIX@SCE, Beth Pickering/SCE/EIX@SCE, BOB CORBETT/SONGS/SCE/EIX@SCE, BOB bcc Subject Attention Required -Dan Breigs e-mail Address All, Effective immediately, Dan's email has changed as follows: Daniel Breig/SCE/EIX Please ensure that you use this address for any future correspondence or meeting invitations.

Thank you, o008 FOCU5:Kirnberly Mendicelli.

Executive Assistant to::Ross T. R idenoure;.Vice President and. S ite. Manager"SCE-SONGS Phone: .(949)368-6920 FAX: (949)368-6183, Kimberly.

K:Mendicelli@sce.

corn; STEVEN To ALLISON SPOLERICH/SONGS/SCE/EIX@SCE JORDANISONGSlSCEIEIX cc LUIS DEL MURO/SONGS/SCE/EIX@SCE 02/22/2008 11:20 AM bcc Subject Fw: TIS/TOES Legacy Functional Specification

-Request Review and or comments by February 29, 2008 Allison, this is another document for Ed's review. This one is the requirements specification from Luis Del Muro the project analyst. I sent the project plan. Hopefully, this clears up any confusion.

This should be the last document Ed will see.Steve Steven Jordan, pax 82296 or (949) 368-2296 IT Solutions Delivery Steven.Jordan(Wsce.com

---

Forwarded by STEVEN JORDAN/SONGS/SCE/EIX on 02/22/2008 11:18 AM --LUIS DEL MUROISONGSISCEIEIX To A. E. SCHERER/SONGS/SCE/EIX@SCE 02/22/2008 10:16 AM cc STEVEN JORDAN/SONGS/SCE/EIX@SCE Subject TIS/TOES Legacy Functional Specification

-Request Review and or comments by February 29, 2008 Ed In previous discussions regarding TIS/TOES SAP rollout 1 impact Caroline McAndews requested I add your name for review from an NOA prespective.

Attached for your review is the Topic Information Server / Topic Operating Experience Search (TIS/TOES)

Legacy Functional Specification

/ Software Requirements Specification.

Please review the attached document and add your comments and or questions to the proposed changes to TIS/TOES in support of SAP rollout 1.Please add any comments and or questions back to me by February 29, 2008 using email or a highlighted marked up copy of the attached file. No response shall be interrupted as no comment or questions.

Please call me if I can help.TIS-TOES-LFS-1N_4038-04 Rev 0.doc Luis Del Muro Southern California Edison Information Technology

-Nuclear Information Services San Onofre Nuclear Generating Station (SONGS)Building G50A Mesa Area Pax 82748 Pager 608628 delmurlg@songs.sce.com 949 368-2748 A 4**4 4 44**44 44** *44*4***44**

• 44**######4**

• 44 4* 44*

• 4 4*

• 4 4* 4* 4######* 4 Job 1614 ** ** 4 * ** 44 Jobe 11:5:5A Southern California Edison ERP Project Legacy Functional Specification

/ Software Requirements Specification TIS/TOES Applications Modifications SAP Rollout 1 Doc ID: TIS-TOES-LFS-IN 4038-04 Status: Revision 0 Process Organization:

SONGS, IT SD&M Prepared by: Luis Del Muro TIS-TOES-LFS-TN 4038-04 Rev O.doc Pagel1 of 8 Ný in J-Table of Contents 1. OVERVIEW SECTION..........................................................................................

3 1.1. Document Change History.............................................................................................................

3 1.2. Document Review .......................................................................................................................

4 1.3. IT Legacy Document Sign Off ........................................................................................................

4 1.4. Open Issues ...............................................................................................................................

4 2. FUNCTIONAL REQUIREMENTS..............................................................................

5 2.1. Purpose and Background

..............................................................................................................

5 2.1.1. In Scope ..............................................................................................................................

5 2.1.2. Out ofScope.........................................................................................................................

6 2.1.3. Alternative(s)........................................................................................................................

6 3. ASSUMPTIONS!

RISKS / CONSTRAINTS...................................................................

6 3.1. Major Assumptions......................................................................................................................

6 3.2. Significant Risks..........................................................................................................................

6 3.3. Constraints................................................................................................................................

7 4. DEPENDENCIES................................................................................................

7 4.1. General 7 ei)en encies ...........................................................................................................................................................

4.2. Related

Legacy Objects ................................................................................................................

7 4.2.1. 115/TOES Applications

............................................................................................................

7 4.2.2. Object Association Table...........................................................................................................

7 4.2.3. Error Handling ......................................................................................................................

7 5. SECURITYISOX CONSIDERATIONS

........................................................................

8 6.ADDITIONAL NOTES...........................................................................................

8 TIS-TOES-LFS-IN 4038-04 Rev 0.doc Page 2 of 8 TIS-TOES-LFS-fN 4038-04 Rev O.doc Page 2 of 8 1.Overview Section ,.Corresponding FDS J-! N/Aýdocument(s):

SDM LegacynSME(s):

Luis Del Muro Type of Work TIS/TOES Application modifications for SAP Rollout 1: Topic Information Server / Topic Operating Experience Search ARMSAPPL ACRN(s) TIS/TOES Business Unit To Perform Work IT SD&M Legacy 6Complexity , Medium < or = 399 hours0.00462 days <br />0.111 hours <br />6.597222e-4 weeks <br />1.518195e-4 months <br />.Assumption:

High Level Design thru Code/Unit Test ,SoftwareClassification, .Mediuminformation

<which rollout Willthis1beexecutedin>, .. RO 2 R1 Li R2 E] R3 LI R4 El Release Independent IISecurity

/SOX E]Li Yes E No If yes, refer to Section 5 for details=Date Needed For ERP Integration Not Applicable Testing 1.1. Document Change History Date Created Brief Description&ofChange 2.' Doc ,version Created I Modified By Modified Oct 16, 2007 Luis Del Muro New A Feb 15, 2008 Luis Del Muro Identified limitation of SAP search tool (TREX) 0 TIS-TOES-LFS-IN-4038-04 Rev O.doe Page 3 of 8

/1.2. Document Review Rev'iewed By: ~4 The -Reviewed B\" sighatirdicates the inidividual(s Iho rceiwedthtis document fori clarty, and totbt their knolde, thIs d mnt presents a technicall fNeasibI ILit ind I corporatompees wlt Ttcorporate

& ero policies and procedures ucer rariato TitlelRole

• Na&me of Reviewer Signature Approval Date*IT SDM/TIS/ITOES SME Luis Del Muro IT SDM Developer Joe Lee Review Only ERP/SAP Team Legacy Applications Doug Cooper Review Only IT SDM SIOC Joel Keown ERP/GBU Organizational Change Jim Madigan Review Only Management GBU Nuclear Organization

-Nuclear Deborah Lindbeck Review Only Training Division Director Nuclear Regulatory Affairs A. Edward Scherer Review Only 1.3. IT Legacy Document Sign Off Approved By:.The -'Approved By' Signa1itirinicte the iniv~iidual(s) whIo approved., this" document for ý1cntent11d,1

'Ity~nd toý the(:hst of Lheir know~cLed this,,documecont

ý vi.ith : co orate policies rocedures:

Title/Role Naeof Approver Signature Approval Date GBU Nuclear Organization

-CFDM Michael P. Short TIS/TOES Operating Experience GBU Nuclear Organization

-System Michael A. Jones Sponsor TIS/TOES Operating Experience SIOC Manager NDMS -SDM Joel Keown GBU Nuclear Organization

-CFDM TIS Pam Panek GBU Nuclear Organization

-System Susan Hunn Sponsor TIS ERP SAP GBU Business Process Team -Jim Demlow Corrective Action Program ERP EAM GBU DM RM Project Manager David Briley Project Manager/IT Solutions Delivery Steve Jordan 1.4. Open Issues-I TIS-TOES-LFS-IN_4038-04 Rev 0.doc Page 4 of 8

2. Functional Requirements

2.1. Purpose

and Background Communicate and identify the software modifications to the TOES application resulting from the implementation of the full text indexing and search capabilities associated with SAP rollout 1.San Onofre Nuclear Generating Station (SONGS) Human Performance programs sets the expectation for regular use and review of operating experience and lessons learned information.

Nuclear workers are required to search internal web-based sites that contain operating experience and lessons learned events, they are also required to search United States Nuclear Regulatory Commission (USNRC) and Institute of Nuclear Power Organization (INPO) databases.

This required the nuclear worker to perform multiple searches using multiple search engines. With the implementation of Topic Operation Experience Search (TOES) Phase I all internal operating experience and lessons learned contained in the Maintenance, Operations, Station Technical and Administration Integrated Computer System (MOSAIC) were consolidated in TOES.The Topic Operation Experience Search (TOES) Phase II project implemented a web-based single search tool providing access to all internal data from San Onofre Nuclear Generating Station (SONGS) and external nuclear industry operating experience data from Institute of Nuclear Power Organization (INPO) and United States Nuclear Regulatory Commission (USNRC) databases.

A single search tool provided more consistent results, simplified and improved access to OE documents and significantly reduced the time required to perform the searches required to satisfy SONGS Human Performance programs.

TOES OE and lessons learned data is a subset (above 37%) of a larger indexed data repository for the search tool called Topic Information Server (TIS), TOES Phase II also provided the OE searcher the capability to only search OE related data bypassing all other none OE information thereby returning the search results faster and with a higher degree of pertinent results.With the implementation of SAP Rollout I Mosaic and NDMS are moving to SAP thereby removing the ability to extract specific OE and lesson learned related data from Mosaic. This will reduce the data indexed in TOES; it will require the nuclear worker to use another search engine in SAP, retreating back to former years where the use of multiple search engines was the standard.

Yet to be proven is the ability to successfully search using the SAP search engine (TREX) and retrieve relevant and specific information.

The SAP search engine has demonstrated it can index most of the OE data, but has yet to demonstrate similar search capabilities as were developed in TOES. The SAP developed search tool (TREX)will provide only minimal search capabilities and will require additional search refinements by the user to locate specific information.

Important Distinction TIS and TOES have and use the same database and for all intents and purposes are one application.

Programmatically and with specific user defined data identification, TOES was developed to only use OE and lessons learned related data for all its search queries, thereby eliminating the work effort of the search user to remember the correct syntax and or selection criteria required for capturing the full breadth of the OE and lesson learned information.

Two separate interface screens were developed, one for general search that includes all data including OE and lessons learned and one specific for OE search (37% of all the indexed data in TIS), but keep in mind it's only one database and one application.

Legacy Work Description/Scope 2.1.1. In Scope TIS/TOES software modifications

• Software requirements are not being deleted, added or modified with this software modification, but the indexing and search functions for OE related information is being split between SAP and TOES.* SAP DM RM (Document Management Record Management)

Rollout 1 will include the following:

TIS-TOES-LFS-IN_4038-04 Rev 0.doc Page 5 of 8 The TOES "Internal Sources", MOSAIC Operating Experience selection boxes will remain on the TOES interface screen, but will no longer be updated. The data will be frozen; a note will be placed next to the selection boxes indicating that OE data is now split and contained in both SAP and TOES. The use of multiple search engines will be required to review all OE data.* SAP DM RM Rollout I will include the following

-Remove search access to selection boxes on the TIS/TOES search screen, they are: Nuclear Document Management System (NDMS -All Procedures

& Romans and Nuclear Training)NDMS Procedures Only Roman Numeral Procedures NDMS Nuclear Training NDMS Drawings" Add messages to the help screen identifying all search sections removed due to SAP DM RM implementation and the split of OE related data.2.1.2. Out of Scope Modifications to TIS/TOES application that are not addressed in Section 2.1.1 are out of scope.2.1.3. Alternative(s)" Maintain Operating Experience searching in a single application, i.e. TIS/TOES" Provide an outbound SAP interface to TIS/TOES for internal lesson learned data" Provide an outbound SAP interface to TIS for procedure data 3. Assumptions/

Risks / Constraints

3.1. Major

Assumptions" GBU Operating Experience CFDM & Program Manager (System Sponsor) approve of the splitting of the Operating Experience search capability between SAP and TIS/TOES" Can SAP provide full text indexing and search capabilities similar to TIS/TOES.

Early presentation of SAP (TREX) search tool demonstration limited search capabilities and no searched word highlights." TIS/TOES to SAP interface are not required." ERP Organization Change Management team facilitates the changes to the Nuclear Organization as a result of splitting the Operating Experience search capability between search software applications." TOES CFDM and System Sponsor will implement the changes for OE search in accordance with nuclear procedure S0123-XV-50.7." TOES CFDM and System Sponsor are responsible for business process and procedure changes resulting from modifications to TOES affecting how the nuclear organization searches for OE related data.3.2. Significant Risks Risk I Potential Project Impact I Mitigation Strategies TIS-TOES-LFS-IN_4038-04 Rev 0.doc Page 6 of 8 Business Process Risk 1. No legacy development project 1. ERP Business Process Lead for 1. Functionality of SAP impact; however there is a Corrective Action Program review the search tool meeting OE potential for Increase to ERP Operating Experience search strategy search needs and the project cost resulting from with business CFDM & Program NDMS and NTD NDMS additional analyst, developer

& Manager (System Sponsor)user community.

tester allocation to compensate for providing search capabilities in 2. Nuclear Organization business SAP for OE and procedure source process owner & stakeholders review files. associated software development lifecycle documents implementing the 2. SAP to TIS/TOES interface may legacy application modifications.

be required if SAP can not support OE business needs.Business Process Risk No legacy development project Inform TOES CFDM and System 2. Nuclear organization is impact. Sponsor of SAP RI impact to OE required to use multiple search process.search engines to locate Impact is to business unit due to OE related data. use of multiple search engines.3.3. Constraints Legacy application software modifications must be implemented in support of this rollout. ERP business process lead identify go / no go decision for full text indexing support of SAP OE and procedure source files.Change Request 1758 will be modified and approved which mandates the implementation of Operating Experience searching capability using multiple software applications.

Agreement by the TOES System Sponsor that splitting OE and lessons learned data is acceptable.

Give proper notification to nuclear organization workers that multiple search engines are required to satisfy the SONGS Human Performance program and organizational change management conveys the new process.4. Dependencies

4.1. General

Dependencies Tester has access and training required to test TIS/TOES application software, data and security in this release.4.2. Related Legacy Objects 4.2.1.TIS/TOES Applications Short Name Long Name Accessed By TIS Topic Information Server USER TOES Topic Operating Experience Search USER 4.2.2.Object Association Table 4.2.3.Error Handling Page 7 of 8 TIS-TOES-LFS-IN-4038-04 Rev O.doc Existing error handling in the TIS/TOES applications will not be altered by this project. Software and data modifications only restrict access and do not add, modify or delete existing functions.

5. Security/SOX Considerations Testers and Test IDs must have network access to TIS/TOES. (comment -identify what TIS/TOES resource and roles would be required for users & respective testers)TIS/TOES are not classified as a SOX related application.

6. Additional Notes N/A Page 8 of 8 TIS-TOES-LFS-IN-4038-04 Rev O.doc fttf f ffttff fftt tfftftttfftt tfftt######ftt tff ft ### ft## ft## ft# ft ft# ft# ft# ft f#t f Job ft 131fftff f t ftt f Jobe 131402A ftftft ftftft ftftft##ft ftftft ftftft ft ft ft ft ft ft ft ft ftft ft ft ftft ftftft ft ft ftftft ft# ft ft# ft ft ft ft ft ft ft ft ft ft ft ft ft ft ftftft ftft ftftftftftft ftftftftftft ftftftftftft ftftft ftftft ftftft ftftft ftftft ft ft ftftftft ft ftft ftftftft ft ftft ftftft ft ft ftftft ft ft ft ft ft ft ft ft ft ft ft ftftft ftftft ftftft ftftftftftft Job : 242 Date: 2/22/2008 Time: 10:52:42 AM

1. 1. 1. 1. 1. ###444 444 444 444 444 4 4 #444 4 44 4444 4 44 444 4 4 444 4 4 4 4 4 4 4 4 4 4 4 444 444 444 444444 Job : 44 Date: 2/22/2008 Time: 10:56:49 AM fttf f ffttff fftt tfftftttfftt tfftt######ftt tff ft ~ ~ ~ ~ ~ ### ###ft f#t#t# f t ft f t t f Job :157 Date: 2/22/2008 Time: 11:51:21 AM