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| | number = ML13015A004 | | | number = ML13015A004 |
| | issue date = 01/10/2013 | | | issue date = 01/10/2013 |
| | title = San Onofre, Unit 2, Response to Request for Additional Information (RAI 16), Regarding Confirmatory Action Letter Response (TAC No. Me 9727) | | | title = Response to Request for Additional Information (RAI 16), Regarding Confirmatory Action Letter Response (TAC No. Me 9727) |
| | author name = St-Onge R J | | | author name = St-Onge R |
| | author affiliation = Southern California Edison Co | | | author affiliation = Southern California Edison Co |
| | addressee name = | | | addressee name = |
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| {{#Wiki_filter:JSOUTHERN CALIFORNIAEDISONAn EDISON INTERNATIONAL CompanyRichard 1. St. OngeDirector, Nuclear Regulatory Affairs andEmergency PlanningJanuary 10, 201310 CFR 50.4U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001Subject:Docket No. 50-361Response to Request for Additional Information (RAI 16)Regarding Confirmatory Action Letter Response(TAC No. ME 9727)San Onofre Nuclear Generating Station, Unit 2References:1. Letter from Mr. Elmo E. Collins (USNRC) to Mr. Peter T. Dietrich (SCE), datedMarch 27, 2012, Confirmatory Action Letter 4-12-001, San Onofre NuclearGenerating Station, Units 2 and 3, Commitments to Address Steam GeneratorTube Degradation2. Letter from Mr. Peter T. Dietrich (SCE) to Mr. Elmo E. Collins (USNRC), datedOctober 3, 2012, Confirmatory Action Letter -Actions to Address SteamGenerator Tube Degradation, San Onofre Nuclear Generating Station, Unit 23. Letter from Mr. James R. Hall (USNRC) to Mr. Peter T. Dietrich (SCE), datedDecember 26, 2012, Request for Additional Information Regarding Responseto Confirmatory Action Letter, San Onofre Nuclear Generating Station, Unit 2Dear Sir or Madam,On March 27, 2012, the Nuclear Regulatory Commission (NRC) issued a Confirmatory ActionLetter (CAL) (Reference 1) to Southern California Edison (SCE) describing actions that the NRCand SCE agreed would be completed to address issues identified in the steam generator tubesof San Onofre Nuclear Generating Station (SONGS) Units 2 and 3. In a letter to the NRC datedOctober 3, 2012 (Reference 2), SCE reported completion of the Unit 2 CAL actions andincluded a Return to Service Report (RTSR) that provided details of their completion.By letter dated December 26, 2012 (Reference 3), the NRC issued Requests for AdditionalInformation (RAIs) regarding the CAL response. Enclosure 1 of this letter provides theresponse to RAI 16.P.O. Box 128San Clemente, CA 92672 Document Control Desk-2-January 10, 2013There are no new regulatory commitments contained in this letter. If you have any questions orrequire additional information, please call me at (949) 368-6240.Sincerely,Enclosures:1. Response to RAI 16cc:E. E. Collins, Regional Administrator, NRC Region IVR. Hall, NRC Project Manager, San Onofre Units 2 and 3G. G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 and 3R. E. Lantz, Branch Chief, Division of Reactor Projects, NRC Region IV ENCLOSURE ISOUTHERN CALIFORNIA EDISONRESPONSE TO REQUEST FOR ADDITIONAL INFORMATIONREGARDING RESPONSE TO CONFIRMATORY ACTION LETTERDOCKET NO. 50-361TAC NO. ME 9727Response to RAI 16Page 1 RAI 16Reference 1, Section 9.3, page 50 -Provide additional information concerning the "OperationalDecision Making" process and describe how it would be applied if the proposed criterion isexceeded. Provide the procedural action statement.RESPONSEReference 1, Section 9.3 states: "The plant procedure for chemical control of primary plant andrelated systems has been modified to require action if the specific activity of the reactor coolantDose Equivalent Iodine (DE 1-131) exceeds the normal range of 0.5 pCi/gm, which is one-half ofthe TS Limit of 1.0 pCi/gm. In the event that the normal range is exceeded, Operations isrequired to initiate the Operational Decision Making process to evaluate continued plantoperation."Operational Decision Making ProcessThe San Onofre Nuclear Generating Station (SONGS) Operational Decision Making (ODM)process is based on the Institute of Nuclear Power Operations (INPO) 2011 document,"Principles for Effective ODM," which was developed by an industry task force with assistancefrom INPO and U.S nuclear utility managers and executives.SONGS ODM procedure provides the Operations Shift Manager (SM) and station leadership aframework for making decisions in response to degraded conditions to address long termprotection of the public, plant personnel and station assets. Two scenarios are addressed bythe ODM process: Type 1 off-normal conditions and Type 2 degraded conditions that fall belowthe action thresholds defined in license documents or may not be defined in existingprocedures.The ODM process provides checklists with specified considerations the SM uses to ensure athorough review of the degraded condition is performed and documented. A list of stakeholdersis included to facilitate involvement of required subject matter experts and personnel. Thepurpose of these lists is to provide an established format to address trends, assessments, risks,plant conditions, regulatory commitments, and impacts of the degraded condition to ensure thehealth and safety of the public. The ODM process results in operational decisions,implementation plans and thresholds to trigger actions.Establishment of Administrative Limit for RCS DE 1-131 Activity LevelChemistry procedure, "Units 2/3 Chemical Control of Primary Plant and Related Systems," hasbeen revised to lower the Reactor Coolant System (RCS) DE 1-131 limit from 1.0 pCi/gm to0.5 pCi/gm. The Technical Specification (TS) limit for DE 1-131 is 1.0 pCi/gm. As a defense indepth action included in the Unit 2 return to service plan, if DE 1-131 exceeds the Normal RangeLimit of 0.5 pCi/gm, Chemistry personnel will perform sampling for DE 1-131 once every fourhours until the level is less than 0.5 pCi/gm. In addition, Chemistry personnel are directed tonotify the on-shift Operators to initiate a Type 1 0DM evaluation to determine other appropriateactions to be taken. For this off-normal condition, the ODM will be performed to determine theimpact of the increasing levels of DE 1-131 and involve senior station management in evaluatingcontinued plant operation. If DE 1-131 exceeds 0.5 pCi/gm for greater than 48 hours, a plantshutdown to Mode 3 will commence with Tavg less than 500°F within 6 hours (as required byTSs when DE 1-131 exceeds 1.0 pCi/gm). The procedural actions, frequency, and range areshown in the table below.Page 2 Using the ODM process, the SM obtains data from (1) Chemistry Department representativesas to the nature of the increasing DE 1-131, (2) Nuclear Fuels group concerning the condition ofthe nuclear fuel pins that would be the source of the increased activity, and (3) engineeringpersonnel regarding the condition of the steam generators. Based on the input from thestakeholders, the SM confers with Station Management to decide future actions, including apotential plant shutdown prior to being procedurally required.Chemistry Procedure RCS Activity Level Action StatementParameter Frequency Normal Comments/Corrective ActionRangeITS SR 3.4.16.2Mode 1 requirement for non-transient sample is onceWeekly per 14 days.TS 3.4.16VERIFY within 2 to 6 hours following a thermal powerchange -15% of the rated power within a one-hourperiod.IF DE 1-131 EXCEEDS the Normal Range (< 0.5DE 1-131, pCi/gm), THEN send a Memo to Operations requestingDE 1-11, < a Type 1 0DM be performed to continue plantpCi/gm -0.5 operation considering Steam Generator health."TS 3.4.16 pCi/gmIF DE 1-131 EXCEEDS the Normal Range Limit (5 0.5SR 3.4.16.2 With >15% pCi/gm ), THEN SAMPLE and analyze the RCS everypower four hours until < 0.5 pCi/gmchange/hourNOTE: Actual Tech Spec Limit is > 1.0 pCi/gm,however, TS required Actions shall be performed at> 0.5 pCi/gmIF DE 1-131 is > 0.5 pCi/gm for greater than 48 hoursOR greater than the limits of Figure 3.4.16-1 at anytime, THEN be in Mode 3 with Tavg <5000F within 6hours.Page 3 | | {{#Wiki_filter:Richard 1. St. Onge JSOUTHERN EDISON CALIFORNIA An EDISON INTERNATIONAL Company Director, Nuclear Regulatory Affairs and Emergency Planning January 10, 2013 10 CFR 50.4 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 |
| }} | | |
| | ==Subject:== |
| | Docket No. 50-361 Response to Request for Additional Information (RAI 16) |
| | Regarding Confirmatory Action Letter Response (TAC No. ME 9727) |
| | San Onofre Nuclear Generating Station, Unit 2 |
| | |
| | ==References:== |
| | : 1. Letter from Mr. Elmo E. Collins (USNRC) to Mr. Peter T. Dietrich (SCE), dated March 27, 2012, Confirmatory Action Letter 4-12-001, San Onofre Nuclear Generating Station, Units 2 and 3, Commitments to Address Steam Generator Tube Degradation |
| | : 2. Letter from Mr. Peter T. Dietrich (SCE) to Mr. Elmo E. Collins (USNRC), dated October 3, 2012, Confirmatory Action Letter - Actions to Address Steam Generator Tube Degradation, San Onofre Nuclear Generating Station, Unit 2 |
| | : 3. Letter from Mr. James R. Hall (USNRC) to Mr. Peter T. Dietrich (SCE), dated December 26, 2012, Request for Additional Information Regarding Response to Confirmatory Action Letter, San Onofre Nuclear Generating Station, Unit 2 |
| | |
| | ==Dear Sir or Madam,== |
| | |
| | On March 27, 2012, the Nuclear Regulatory Commission (NRC) issued a Confirmatory Action Letter (CAL) (Reference 1) to Southern California Edison (SCE) describing actions that the NRC and SCE agreed would be completed to address issues identified in the steam generator tubes of San Onofre Nuclear Generating Station (SONGS) Units 2 and 3. In a letter to the NRC dated October 3, 2012 (Reference 2), SCE reported completion of the Unit 2 CAL actions and included a Return to Service Report (RTSR) that provided details of their completion. |
| | By letter dated December 26, 2012 (Reference 3), the NRC issued Requests for Additional Information (RAIs) regarding the CAL response. Enclosure 1 of this letter provides the response to RAI 16. |
| | P.O. Box 128 San Clemente, CA 92672 |
| | |
| | Document Control Desk January 10, 2013 There are no new regulatory commitments contained in this letter. If you have any questions or require additional information, please call me at (949) 368-6240. |
| | Sincerely, |
| | |
| | ==Enclosures:== |
| | : 1. Response to RAI 16 cc: E. E. Collins, Regional Administrator, NRC Region IV R. Hall, NRC Project Manager, San Onofre Units 2 and 3 G. G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 and 3 R. E. Lantz, Branch Chief, Division of Reactor Projects, NRC Region IV |
| | |
| | ENCLOSURE I SOUTHERN CALIFORNIA EDISON RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING RESPONSE TO CONFIRMATORY ACTION LETTER DOCKET NO. 50-361 TAC NO. ME 9727 Response to RAI 16 Page 1 |
| | |
| | ===RAI 16=== |
| | Reference 1, Section 9.3, page 50 - Provide additional information concerning the "Operational Decision Making" process and describe how it would be applied if the proposed criterion is exceeded. Provide the procedural action statement. |
| | |
| | ===RESPONSE=== |
| | Reference 1, Section 9.3 states: "The plant procedure for chemical control of primary plant and related systems has been modified to require action if the specific activity of the reactor coolant Dose Equivalent Iodine (DE 1-131) exceeds the normal range of 0.5 pCi/gm, which is one-half of the TS Limit of 1.0 pCi/gm. In the event that the normal range is exceeded, Operations is required to initiate the Operational Decision Making process to evaluate continued plant operation." |
| | Operational Decision Making Process The San Onofre Nuclear Generating Station (SONGS) Operational Decision Making (ODM) process is based on the Institute of Nuclear Power Operations (INPO) 2011 document, "Principles for Effective ODM," which was developed by an industry task force with assistance from INPO and U.S nuclear utility managers and executives. |
| | SONGS ODM procedure provides the Operations Shift Manager (SM) and station leadership a framework for making decisions in response to degraded conditions to address long term protection of the public, plant personnel and station assets. Two scenarios are addressed by the ODM process: Type 1 off-normal conditions and Type 2 degraded conditions that fall below the action thresholds defined in license documents or may not be defined in existing procedures. |
| | The ODM process provides checklists with specified considerations the SM uses to ensure a thorough review of the degraded condition is performed and documented. A list of stakeholders is included to facilitate involvement of required subject matter experts and personnel. The purpose of these lists is to provide an established format to address trends, assessments, risks, plant conditions, regulatory commitments, and impacts of the degraded condition to ensure the health and safety of the public. The ODM process results in operational decisions, implementation plans and thresholds to trigger actions. |
| | Establishment of Administrative Limit for RCS DE 1-131 Activity Level Chemistry procedure, "Units 2/3 Chemical Control of Primary Plant and Related Systems," has been revised to lower the Reactor Coolant System (RCS) DE 1-131 limit from 1.0 pCi/gm to 0.5 pCi/gm. The Technical Specification (TS) limit for DE 1-131 is 1.0 pCi/gm. As a defense in depth action included in the Unit 2 return to service plan, if DE 1-131 exceeds the Normal Range Limit of 0.5 pCi/gm, Chemistry personnel will perform sampling for DE 1-131 once every four hours until the level is less than 0.5 pCi/gm. In addition, Chemistry personnel are directed to notify the on-shift Operators to initiate a Type 1 0DM evaluation to determine other appropriate actions to be taken. For this off-normal condition, the ODM will be performed to determine the impact of the increasing levels of DE 1-131 and involve senior station management in evaluating continued plant operation. If DE 1-131 exceeds 0.5 pCi/gm for greater than 48 hours, a plant shutdown to Mode 3 will commence with Tavg less than 500°F within 6 hours (as required by TSs when DE 1-131 exceeds 1.0 pCi/gm). The procedural actions, frequency, and range are shown in the table below. |
| | Page 2 |
| | |
| | Using the ODM process, the SM obtains data from (1) Chemistry Department representatives as to the nature of the increasing DE 1-131, (2) Nuclear Fuels group concerning the condition of the nuclear fuel pins that would be the source of the increased activity, and (3) engineering personnel regarding the condition of the steam generators. Based on the input from the stakeholders, the SM confers with Station Management to decide future actions, including a potential plant shutdown prior to being procedurally required. |
| | Chemistry Procedure RCS Activity Level Action Statement Parameter Frequency Normal Comments/Corrective Action RangeI TS SR 3.4.16.2 Mode 1 requirement for non-transient sample is once Weekly per 14 days. |
| | TS 3.4.16 VERIFY within 2 to 6 hours following a thermal power change - 15% of the rated power within a one-hour period. |
| | IF DE 1-131 EXCEEDS the Normal Range (< 0.5 DE 1-131, pCi/gm), THEN send a Memo to Operations requesting DE 1-11, < a Type 1 0DM be performed to continue plant pCi/gm - 0.5 operation considering Steam Generator health. |
| | "TS 3.4.16 pCi/gm IF DE 1-131 EXCEEDS the Normal Range Limit (5 0.5 SR 3.4.16.2 With >15% pCi/gm ), THEN SAMPLE and analyze the RCS every power four hours until < 0.5 pCi/gm change/hour NOTE: Actual Tech Spec Limit is > 1.0 pCi/gm, however, TS required Actions shall be performed at |
| | > 0.5 pCi/gm IF DE 1-131 is > 0.5 pCi/gm for greater than 48 hours OR greater than the limits of Figure 3.4.16-1 at any time, THEN be in Mode 3 with Tavg <5000 F within 6 hours. |
| | Page 3}} |
Letter Sequence Response to RAI |
|---|
|
Initiation
- Request, Request, Request, Request, Request, Request, Request
- Acceptance
- Supplement, Supplement, Supplement, Supplement, Supplement, Supplement
|
MONTHYEARML12285A2652012-10-0101 October 2012
Attachment 4 - MHI Document L5-04GA564 - Tube Wear of Unit-3 RSG, Technical Evaluation Report
Project stage: Request
ML12285A2672012-10-0101 October 2012
Attachment 4: SG Tube Wear Analysis for Unit-2/3
Project stage: Request
ML12285A2662012-10-0101 October 2012
Attachment 4: Appendix-2 Attachment-1, Tube-to-TSP Wear Depth Diagram for Unit-2/3
Project stage: Request
ML12285A2642012-10-0101 October 2012
Attachment 3 - Areva Document 51-9180143-001 - SONGS Unit 3 February 2012 Leaker Outage Steam Generator Condition Monitoring Report
Project stage: Request
ML12285A2682012-10-0202 October 2012
Attachment 6 - Appendix B: SONGS U2C17 - Steam Generator Operational Assessment for Tube-to-Tube Wear
Project stage: Request
ML12285A2692012-10-0202 October 2012
Attachment 6: Appendix a: Estimates of FEI-Induced Ttw Rates
Project stage: Request
ML12285A2632012-10-0303 October 2012
Confirmatory Action Letter - Actions to Address Steam Generator Tube Degradation
Project stage: Request
ML12338A1102012-11-30030 November 2012
Email, Request for Additional Information Southern California Edison'S Response to Nrc'S Confirmatory Action Letter (CAL) 4-12-001 Dated March 27, 2012
Project stage: RAI
ML12341A1122012-12-0707 December 2012
Notice of Meeting with Southern California Edison to Discuss Its Response to Nrc'S Confirmatory Action Letter and Return to Service Report for San Onofre Nuclear Generating Station, Unit 2
Project stage: Meeting
ML12347A0662012-12-0707 December 2012
Revised Notice of 12/18/12 Meeting with Southern California Edison to Discuss Its Response to Nrc'S Confirmatory Action Letter and Return to Service Report for San Onofre Nuclear Generating Station, Unit 2
Project stage: Meeting
ML12345A4272012-12-10010 December 2012
Revised Email, Request for Additional Information Review of Southern California Edison'S Response to Nrc'S 3/27/2012 Confirmatory Action Letter (CAL) 4-12-001 and Return to Service Report
Project stage: RAI
ML12353A0972012-12-13013 December 2012
LTR-12-0795 - E-mail Don Leichtling Concerns Media Alert - Nuclear News - NRR Forthcoming Meeting with Southern California Edison Company
Project stage: Meeting
ML12352A3852012-12-18018 December 2012
Licensee Slides for 12/18/12 Public Meeting
Project stage: Meeting
ML12352A4112012-12-18018 December 2012
NRC Slides for 12/18/12 Meeting with Southern California Edison
Project stage: Meeting
ML12356A1982012-12-20020 December 2012
Email, Request for Additional Information, Round 3, Review of Southern California Edison'S Response to Nrc'S 3/27/2012 Confirmatory Action Letter (CAL) 4-12-001 and Return to Service Report
Project stage: RAI
ML13009A3492013-01-0808 January 2013
Response to Request for Additional Information Regarding Confirmatory Action Letter Response
Project stage: Response to RAI
ML13014A2512013-01-0909 January 2013
Response to Request for Additional Information (RAI 30) Regarding Confirmatory Action Letter Response
Project stage: Response to RAI
ML13014A2492013-01-0909 January 2013
Response to Request for Additional Information (RAI 15) Regarding Confirmatory Action Letter Response
Project stage: Response to RAI
ML13015A0042013-01-10010 January 2013
Response to Request for Additional Information (RAI 16), Regarding Confirmatory Action Letter Response (TAC No. Me 9727)
Project stage: Response to RAI
ML13022A0882013-01-16016 January 2013
Response to Request for Additional Information (RAI 19) Regarding Confirmatory Action Letter Response (TAC No. Me 9727)
Project stage: Response to RAI
ML13022A4132013-01-17017 January 2013
Response to Request for Additional Information (RAIs 10 and 17) Regarding Confirmatory Action Letter Response
Project stage: Response to RAI
ML13022A4812013-01-18018 January 2013
Response to Request for Additional Information (RAI 13), Regarding Confirmatory Action Letter Response
Project stage: Response to RAI
ML13022A4082013-01-18018 January 2013
Response to Request for Additional Information (RAI 12), Regarding Confirmatory Action Letter Response (TAC No. Me 9727)
Project stage: Response to RAI
ML13022A4112013-01-21021 January 2013
Response to Request for Additional Information (RAI 11) Regarding Confirmatory Action Letter Response (TAC Me 9727)
Project stage: Response to RAI
ML13022A4052013-01-21021 January 2013
Response to Request for Additional Information (RAI 28), Regarding Confirmatory Action Letter Response (TAC No. Me 9727)
Project stage: Response to RAI
ML13028A0982013-01-24024 January 2013
Response to Request for Additional Information (RAI 18) Regarding Confirmatory Action Letter Response
Project stage: Response to RAI
ML13028A4752013-01-25025 January 2013
Response to Request for Additional Information (RAI 27) Regarding Confirmatory Action Letter
Project stage: Response to RAI
ML13028A4742013-01-25025 January 2013
Response to Request for Additional Information (RAIs 5, 7, and 9) Regarding Confirmatory Action Letter Response
Project stage: Response to RAI
ML13032A0092013-01-29029 January 2013
Response to Request for Additional Information (RAI 14) Regarding Confirmatory Action Letter Response (TAC No. Me 9727)
Project stage: Response to RAI
ML13037A1122013-01-31031 January 2013
Response to Request for Additional Information (RAI 29) Regarding Confirmatory Action Letter Response
Project stage: Response to RAI
ML13053A3672013-02-0101 February 2013
E-mail, Draft Request for Additional Information Southern California Edison'S Response to Nrc'S Confirmatory Action Letter
Project stage: Draft RAI
ML13038A0102013-02-0404 February 2013
Response to Request for Additional Information (RAI 8) Regarding Confirmatory Action Letter Response
Project stage: Response to RAI
ML13038A0092013-02-0404 February 2013
Response to Request for Additional Information (RAI 6) Regarding Confirmatory Action Letter Response
Project stage: Response to RAI
ML13039A2782013-02-0606 February 2013
Response to Request for Additional Information (RAIs 20, 21, 22, 23, 24, 26 & 31), Confirmatory Action Letter
Project stage: Response to RAI
ML13039A3172013-02-0707 February 2013
Response to Request for Additional Information (RAI 25) Regarding Confirmatory Action Letter Response
Project stage: Response to RAI
ML13050A1892013-02-14014 February 2013
Supplemental Document Submittal Regarding Confirmatory Action Letter Response, Concerning Steam Generator Tubes
Project stage: Supplement
ML13051A1972013-02-15015 February 2013
Enclosure 6, LTR-SGDA-12-36, Rev. 3, Flow-Induced Vibration and Tube Wear Analysis of the San Onofre Nuclear Generating Station Unit 2 Replacement Steam Generators Supporting Restart. Cover Through Page 227 of 415
Project stage: Other
ML13051A1992013-02-15015 February 2013
Enclosure 6, LTR-SGDA-12-36, Rev. 3, Flow-Induced Vibration and Tube Wear Analysis of the San Onofre Nuclear Generating Station Unit 2 Replacement Steam Generators Supporting Restart. Page 228 of 415 Through End
Project stage: Other
ML13046A1232013-02-15015 February 2013
2/27/2013 Notice of Forthcoming Meeting with Southern California Edison Company to Discuss Confirmation Action Letter
Project stage: Meeting
ML13051A1932013-02-18018 February 2013
Enclosure 5, L5-04GA585, Rev. 2, Analytical Evaluations for Operational Assessment
Project stage: Other
ML13051A1922013-02-18018 February 2013
Enclosure 4, L5-04GA567, Rev. 6, Evaluation of Stability Ratio for Return to Service
Project stage: Other
ML13051A1902013-02-18018 February 2013
Supplemental Document Submittal Regarding Confirmatory Action Letter Response to Address Steam Generator Tube Degradation
Project stage: Supplement
ML13056A0922013-02-20020 February 2013
Email, Draft Request for Additional Information Nos. 38-52, Southern California Edison'S Response to Nrc'S Confirmatory Action Letter
Project stage: Draft RAI
ML13053A1732013-02-21021 February 2013
Email, Draft Request for Additional Information, Nos. 53-67, Southern California Edison'S Response to Nrc'S Confirmatory Action Letter
Project stage: Draft RAI
ML13053A1842013-02-21021 February 2013
Draft Request for Additional Information, Nos. 53-67, Southern California Edison'S Response to Nrc'S Confirmatory Action Letter
Project stage: Draft RAI
ML13058A0262013-02-25025 February 2013
Response to Request for Additional Information (Rals 2, 3, and 4) Regarding Confirmatory Action Letter Response (TAC No. Me 9727)
Project stage: Response to RAI
ML13056A6012013-02-25025 February 2013
Response to Request for Additional Information (RAI 32) Regarding Confirmatory Action Letter Response
Project stage: Response to RAI
ML13059A1572013-02-27027 February 2013
Licensee Slides from 2/27/13 Meeting Regarding a Request for Additional Information
Project stage: Meeting
ML13059A1522013-02-27027 February 2013
NRC Meeting Slides from 2/27/13 Public RAI Meeting
Project stage: RAI
ML13074A7932013-03-14014 March 2013
Operational Assessment for 100% Power Case Regarding Confirmatory Action Letter Response
Project stage: Other
2013-01-25
[Table View] |
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Category:Letter
MONTHYEARML24022A1492024-01-17017 January 2024
Independent Spent Fuel Storage Installation, Revision 4 to the Physical Security Plan
IR 05000361/20230062023-11-29029 November 2023
NRC Inspection Report 05000361/2023-006 and 05000362/2023-006
ML23333A0682023-11-22022 November 2023
(SONGS) Units 1, 2, 3 and Independent Spent Fuel Storage Installation - Notification of Change in Nuclear Officer
IR 05000361/20230052023-10-11011 October 2023
NRC Inspection Report 05000361/2023005 and 05000362/2023005
ML23276A5942023-09-28028 September 2023
and Independent Spent Fuel Storage Installation - Supplement to Decommissioning Funding Status Reports
ML23268A0922023-09-20020 September 2023
Generation Station, Units 1, 2 and 3, and the Independent Spent Fuel Storage Facility (ISFSI) - Re-Registration of Dry Fuel Storage Casks for Amended Certificate of Compliance No. 1040
IR 05000361/20230012023-09-13013 September 2023
NRC Inspection Report 05000361 2023-001 and 05000362 2023-004
ML23240A5372023-08-18018 August 2023
Confirmatory Survey Activities Summary and Results for the Unit 2 and 3 Intake Structures at the San Onofre Nuclear Generating Station San Clemente CA
ML23129A1802023-06-14014 June 2023
Cover Letter to State of CA on Draft EA Regarding San Onofre ISFSI Updated DFPs
IR 05000361/20230032023-05-31031 May 2023
NRC Inspection Report 05000361/2023003 and 05000362/2023003
IR 05000361/20230022023-05-23023 May 2023
NRC Inspection Report 05000361/2023-002 and 05000362/2023-002
ML23137A1032023-05-11011 May 2023
(Songs), Units 1, 2 and 3, and Independent Spent Fuel Storage Installation - 2022 Annual Radiological Environmental Operating Report
ML23123A0932023-04-28028 April 2023
(Songs), Units 1, 2 and 3, Submittal of Annual Radioactive Effluent Release Report - 2022
ML23230A0882023-04-10010 April 2023
Independent Spent Fuel Storage Installation - Decommissioning Quality Assurance Plan
ML23094A1272023-03-29029 March 2023
Independent Spent Fuel Storage Installation - 10 CFR 50.82(a)(8)(v and VII) and 10 CFR 72.30(c) Decommissioning Funding Status Report 2021
ML23094A1332023-03-29029 March 2023
Nuclear Property Insurance
ML23062A1172023-02-28028 February 2023
Generation Station Units 1, 2 and 3, Annual Radioactive Effluent Release Report for Independent Spent Fuel Storage Installation - 2022
ML22361A1022023-02-24024 February 2023
Reactor Decommissioning Branch Project Management Changes for Some Decommissioning Facilities and Establishment of Backup Project Manager for All Decommissioning Facilities
ML23059A2812023-02-22022 February 2023
(Songs), Units 1, 2 and 3, 2022 Annual Turtle Incidental Take Report
ML23046A3792023-02-22022 February 2023
NRC Inspection Report 050-00361/2023-001 and 050-00362/2023-001
ML23045A2022023-02-0909 February 2023
Submittal of Annual Corporate Financial Reports for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 for Fy Ending June 30, 2022
ML22287A1352023-01-0505 January 2023
Issuance of Exemption from Title 10 of the Code of Federal Regulations Part 72.106(B), Independent Spent Fuel Storage Installation Controlled Area Boundary (L-2021-LLE-0056)
ML22348A0622023-01-0404 January 2023
NRC to SCE, Transmittal of the National Marine Fisheries Service'S December 12, 2022, Letter of Concurrence for Decommissioning of San Onofre Nuclear Generating Statiion, Units 2 and 3
IR 05000206/20220062022-12-15015 December 2022
NRC Inspection Report 05000206/2022006, 05000361/2022-006, and 05000362/2022-006
ML22347A2122022-12-12012 December 2022
NMFS to NRC, Endangered Species Act Section 7(a)(2) Concurrence Letter for Decommissioning of the San Onofre Nuclear Generating Station
ML22340A6652022-12-0505 December 2022
Letter from John Fassell, Chief; Re., State of California Department of Public Health Review and Comments on SONGS Draft Environmental Assessment
ML22333A8192022-11-21021 November 2022
Submittal of San Onofre Nuclear Generating Station, Units 2 and 3, Defueled Safety Analysis Report, Revised November 2022
IR 05000361/20220052022-11-17017 November 2022
NRC Inspection Report 05000361/2022-005 and 05000362/2022-005
ML22301A1462022-10-20020 October 2022
Report of Violations of the National Pollutant Discharge Elimination System Permit San Onofre Nuclear Generating Station (Songs), Units 2 and 3
ML22277A0162022-09-29029 September 2022
Independent Spent Fuel Storage Installation Response to Request for Additional Information Regarding Request for Exemption from 10 CFR 72.106(b)
IR 05000361/20220042022-09-26026 September 2022
NRC Inspection Report 05000361/2022-004 and 05000362/2022-004
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and Independent Spent Fuel Storage Installation (Isfsi), Response to Request for Supplemental Information Regarding Request for Exemption from 10 CFR 72.106(b)
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(Songs), Units 2 and 3 - Annual Corporate Financial Reports
2024-01-17
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Richard 1. St. Onge JSOUTHERN EDISON CALIFORNIA An EDISON INTERNATIONAL Company Director, Nuclear Regulatory Affairs and Emergency Planning January 10, 2013 10 CFR 50.4 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Docket No. 50-361 Response to Request for Additional Information (RAI 16)
Regarding Confirmatory Action Letter Response (TAC No. ME 9727)
San Onofre Nuclear Generating Station, Unit 2
References:
- 1. Letter from Mr. Elmo E. Collins (USNRC) to Mr. Peter T. Dietrich (SCE), dated March 27, 2012, Confirmatory Action Letter 4-12-001, San Onofre Nuclear Generating Station, Units 2 and 3, Commitments to Address Steam Generator Tube Degradation
- 2. Letter from Mr. Peter T. Dietrich (SCE) to Mr. Elmo E. Collins (USNRC), dated October 3, 2012, Confirmatory Action Letter - Actions to Address Steam Generator Tube Degradation, San Onofre Nuclear Generating Station, Unit 2
- 3. Letter from Mr. James R. Hall (USNRC) to Mr. Peter T. Dietrich (SCE), dated December 26, 2012, Request for Additional Information Regarding Response to Confirmatory Action Letter, San Onofre Nuclear Generating Station, Unit 2
Dear Sir or Madam,
On March 27, 2012, the Nuclear Regulatory Commission (NRC) issued a Confirmatory Action Letter (CAL) (Reference 1) to Southern California Edison (SCE) describing actions that the NRC and SCE agreed would be completed to address issues identified in the steam generator tubes of San Onofre Nuclear Generating Station (SONGS) Units 2 and 3. In a letter to the NRC dated October 3, 2012 (Reference 2), SCE reported completion of the Unit 2 CAL actions and included a Return to Service Report (RTSR) that provided details of their completion.
By letter dated December 26, 2012 (Reference 3), the NRC issued Requests for Additional Information (RAIs) regarding the CAL response. Enclosure 1 of this letter provides the response to RAI 16.
P.O. Box 128 San Clemente, CA 92672
Document Control Desk January 10, 2013 There are no new regulatory commitments contained in this letter. If you have any questions or require additional information, please call me at (949) 368-6240.
Sincerely,
Enclosures:
- 1. Response to RAI 16 cc: E. E. Collins, Regional Administrator, NRC Region IV R. Hall, NRC Project Manager, San Onofre Units 2 and 3 G. G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 and 3 R. E. Lantz, Branch Chief, Division of Reactor Projects, NRC Region IV
ENCLOSURE I SOUTHERN CALIFORNIA EDISON RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING RESPONSE TO CONFIRMATORY ACTION LETTER DOCKET NO. 50-361 TAC NO. ME 9727 Response to RAI 16 Page 1
RAI 16
Reference 1, Section 9.3, page 50 - Provide additional information concerning the "Operational Decision Making" process and describe how it would be applied if the proposed criterion is exceeded. Provide the procedural action statement.
RESPONSE
Reference 1, Section 9.3 states: "The plant procedure for chemical control of primary plant and related systems has been modified to require action if the specific activity of the reactor coolant Dose Equivalent Iodine (DE 1-131) exceeds the normal range of 0.5 pCi/gm, which is one-half of the TS Limit of 1.0 pCi/gm. In the event that the normal range is exceeded, Operations is required to initiate the Operational Decision Making process to evaluate continued plant operation."
Operational Decision Making Process The San Onofre Nuclear Generating Station (SONGS) Operational Decision Making (ODM) process is based on the Institute of Nuclear Power Operations (INPO) 2011 document, "Principles for Effective ODM," which was developed by an industry task force with assistance from INPO and U.S nuclear utility managers and executives.
SONGS ODM procedure provides the Operations Shift Manager (SM) and station leadership a framework for making decisions in response to degraded conditions to address long term protection of the public, plant personnel and station assets. Two scenarios are addressed by the ODM process: Type 1 off-normal conditions and Type 2 degraded conditions that fall below the action thresholds defined in license documents or may not be defined in existing procedures.
The ODM process provides checklists with specified considerations the SM uses to ensure a thorough review of the degraded condition is performed and documented. A list of stakeholders is included to facilitate involvement of required subject matter experts and personnel. The purpose of these lists is to provide an established format to address trends, assessments, risks, plant conditions, regulatory commitments, and impacts of the degraded condition to ensure the health and safety of the public. The ODM process results in operational decisions, implementation plans and thresholds to trigger actions.
Establishment of Administrative Limit for RCS DE 1-131 Activity Level Chemistry procedure, "Units 2/3 Chemical Control of Primary Plant and Related Systems," has been revised to lower the Reactor Coolant System (RCS) DE 1-131 limit from 1.0 pCi/gm to 0.5 pCi/gm. The Technical Specification (TS) limit for DE 1-131 is 1.0 pCi/gm. As a defense in depth action included in the Unit 2 return to service plan, if DE 1-131 exceeds the Normal Range Limit of 0.5 pCi/gm, Chemistry personnel will perform sampling for DE 1-131 once every four hours until the level is less than 0.5 pCi/gm. In addition, Chemistry personnel are directed to notify the on-shift Operators to initiate a Type 1 0DM evaluation to determine other appropriate actions to be taken. For this off-normal condition, the ODM will be performed to determine the impact of the increasing levels of DE 1-131 and involve senior station management in evaluating continued plant operation. If DE 1-131 exceeds 0.5 pCi/gm for greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, a plant shutdown to Mode 3 will commence with Tavg less than 500°F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (as required by TSs when DE 1-131 exceeds 1.0 pCi/gm). The procedural actions, frequency, and range are shown in the table below.
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Using the ODM process, the SM obtains data from (1) Chemistry Department representatives as to the nature of the increasing DE 1-131, (2) Nuclear Fuels group concerning the condition of the nuclear fuel pins that would be the source of the increased activity, and (3) engineering personnel regarding the condition of the steam generators. Based on the input from the stakeholders, the SM confers with Station Management to decide future actions, including a potential plant shutdown prior to being procedurally required.
Chemistry Procedure RCS Activity Level Action Statement Parameter Frequency Normal Comments/Corrective Action RangeI TS SR 3.4.16.2 Mode 1 requirement for non-transient sample is once Weekly per 14 days.
TS 3.4.16 VERIFY within 2 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> following a thermal power change - 15% of the rated power within a one-hour period.
IF DE 1-131 EXCEEDS the Normal Range (< 0.5 DE 1-131, pCi/gm), THEN send a Memo to Operations requesting DE 1-11, < a Type 1 0DM be performed to continue plant pCi/gm - 0.5 operation considering Steam Generator health.
"TS 3.4.16 pCi/gm IF DE 1-131 EXCEEDS the Normal Range Limit (5 0.5 SR 3.4.16.2 With >15% pCi/gm ), THEN SAMPLE and analyze the RCS every power four hours until < 0.5 pCi/gm change/hour NOTE: Actual Tech Spec Limit is > 1.0 pCi/gm, however, TS required Actions shall be performed at
> 0.5 pCi/gm IF DE 1-131 is > 0.5 pCi/gm for greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> OR greater than the limits of Figure 3.4.16-1 at any time, THEN be in Mode 3 with Tavg <5000 F within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
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