ML15327A410

San Onofre, Units 2 and 3 - Response to a Request for Additional Information Regarding Amendment Applications 270 and 255, Proposed Changes to Specific Regulatory Guide Commitments

ML15327A410
Person / Time
Site:	San Onofre
Issue date:	11/19/2015
From:	Kay J A Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML15327A410 (24)

Text

I SOUHERNCALIFORNIAAn EDISON, INTERNATIONAL'g CompanyJames A. KayManager, Nuclear RegulatoryAffairsNovember 19, 201510 CFR 50.90U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, D.C. 20555-0001

Subject:

Docket Nos. 50-361 and 50-362Response to a Request for Additional Information regardingAmendment Applications 270 and 255Proposed Changes to Specific Regulatory Guide Commitments SanOnofre Nuclear Generating Station, Units 2 and 3

References:

1)Letter from T. J. Palmisano (SCE) to the U. S. Nuclear RegulatoryCommission (NRC) dated August 20, 2015;

Subject:

Docket Nos. 50-361 and 50-362, Amendment Applications 270 and 255, ProposedChanges to Specific Regulatory Guide Commitments, San OnofreNuclear Generating Station, Units 2 and 3 (ADAMS Accession No.ML1 5236A018)2) Letter from M. Vaaler (NRC) to the T. J. Palmisano (SCE) datedNovember 12, 2015;

Subject:

San Onofre Nuclear GeneratingStation, Units 2 and 3 -Request for Additional Information Regardingthe License Amendment Request to Make Changes to. SpecificRegulatory Guide Commitments Related to the Implementation of"Cold and Dark" Status (ADAMS Accession No. ML15314A321.)

Dear Sir or Madam:

By letter dated August 20, 2015 (Reference 1), Southern California Edison (SCE) submitted aLicense Amendment Request (LAR), consisting of Amendment Applications Nos. 270 and 255,to Facility Operating License Numbers NPF-10 and NPF-15 for San Onofre Nuclear GeneratingStation (SONGS) Units 2 and 3, respectively. The LAR proposed to revise the Updated FinalSafety Analysis Report (UFSAR) to revise specific Regulatory Guide commitments.By letter dated November 12, 2015 (Reference 2), the NRC provided a Request for AdditionalInformation (RAI) regarding Reference 1. The response to the RAI is contained in theenclosure to this letter.AoOF?P. 0. Box 128San Clemente, CA 92672 Document Control Desk-2Noebr1,05-2-.November 19, 2015The additional information provided in the enclosure does not affect the conclusions ofthe No Significant Hazards Consideration or the Environmental Consideration providedin Reference 1.There are no new regulatory commitments in this letter or the Enclosure.If you have any questions or require any additional information, please contact me at(949) 368-7418.Sincerely,

Enclosure:

Response to NRC Request for Additional Informationcc: M. L. Dapas, Regional Administrator, NRC Region IVM. G. Vaaler, NRC Project Manager, SONGS Units 2 & 3S. Y. Hsu, California Department of Public Health, Radiologic Health Branch2 SONGS SPENT FUEL POOL ISLAND LARDRAFT RAI RESPONSESNovember 19, 2015 RAI-SBPB -01: Makeup Water for Leakage EventsA. Describe how leakage through the spent fuel pool liner resulting from the design basiscask drop and light load handling accidents would be managed. Address the actionsspecified in procedures to reduce or eliminate leakage through the leak collectionsystem and the resulting time available to provide makeup water. Provide justificationfor the quality classification of the makeup sources based on the time available formakeup for leakage events.SONGS Response"Describe how leakage through the spent fuel pool liner resulting from the design basiscask drop and light load handling accidents would be managed:"The cask loading area of the pool was designed for a cask drop, and calculationsconclude that the liner would not be penetrated (Reference 2 and 6). The SONGSUFSAR (Section 9.1.2.2) states in part that "The cask loading area of the Spent FuelStorage Pool is designed to withstand the impact loading of a dropped fuel shippingcask from a maximum height of 28 feet 6 inches".The SONGS UFSAR also notes that "Control of liquid leakage from SFP is maintainedby a system of leak chases which are placed behind the spent fuel pool liner plates.The leak chases are connected to drain lines that terminate in the leak detection sump.Observance of leakage from a drain line will allow identification of the general locationof the leakD (Reference 4).Analyzing the cask handling area for potential drops is appropriate even though theCask Handling Crane was upgraded to a 'Single Failure Proof' design (Reference 1).While the crane is Single Failure Proof, the transfer cask containing the multi-purposecanister could be postulated to drop when they are placed on the upper shelf of a caskpool for lifting yoke change-out. Yoke change-out is required because of the verticalclearance differences. During this evolution, the transfer cask and canister are notfully restrained and are postulated to fall back into the lower portion of the cask pool ifan earthquake occurs or it is otherwise tipped back into the pool area.The new fuel and spent fuel storage areas are not exposed to overhead handling ofthe spent fuel cask (Reference 3).SONGS Procedure S023-3-2-11, "Spent Fuel Pool Operations" providesrequirements for handling of loads over the Spent Fuel Pool (Reference 5), and loaddrop accidents were evaluated in the UFSAR Chapter 15 (Reference 6). Substantialprecautions are in place to preclude drops and leaks (including but not limited to safe-load paths, lift height limits, and other administrate and physical barriers). If leakageoccurs the leak chase drains would be monitored to locate the leak. SFP makeupwould be initiated using the existing installed system or any available mitigatingstrategy flow paths."Address the actions specified in procedures to reduce or eliminate leakage through theleak collection system and the resulting time available to provide mnakeup water:."November 19, 2015 Any leaks (from corrosion or other causes) into a leak chase would be limited toapproximately 50 gpm based on their cross-sectional area. Such leaks would beexpected to start much slower and be detected well before reaching even that flowrate, which is well-within SFP make-up capability. Finally, such small leaks can bemitigated by shutting the leak chase drain valves if and when it was appropriate to doSO.SONGS procedure SO23-3-2.11 governs the normal operation of the Spent Fuel Pool(SFP). Attachment 21 provides 'REQUIREMENTS' for monitoring SFP temperature,level, and limiting loads over the SFP racks (Reference 5). If REQUIREMENTS arenot met, then, Operations suspends all activities involving SFP decay heat load, ANDmonitors temperatures, AND initiates actions to restore the components. If a leak isidentified in the Cask Pool area, there is an isolation gate that can be slid into placeand its inflatable seal pressurized in accordance with Attachments 8 or 9.SONGS Procedure SO23-13-23, "Loss of Spent Fuel Pool Cooling" includes thepotential event of "Loss of SFP Inventory" (Reference 7). Should SFP level drop,Section 2 provides actions and 'actions if response not obtained.' These includeplacing any suspended fuel assembly in a safe position, suspending all fuel movement,initiating SO23-13-20, "Abnormal Operating Instruction, Fuel Handling Accidents orLoss of SFP Level Control" (Reference 8), verifying siphon breaker is covered, andmonitoring/restoring boron concentration. Exit conditions from this procedure are SEPLevel > 23', SEP cooling restored, SEP temperature <140 Degrees F and stable, andpowered from Offsite Power (Exit Conditions Section).SONGS SO23-13-20 "Abnormal Operating Instruction, Fuel Handling Accidents orLoss of SEP Level Control" (Reference 8) specifies similar corrective actions for lossof level.SONGS SO23-V-5.100 "Songs Mitigating Strategies" (Reference 9) provides multipleoptions for providing SFP Makeup, depending on the circumstances that resulted inentering the procedure (i.e., Fire, Security issue, mechanical loss of inventory, etc.)."Provide justification for the quality classification of the makeup sources based on the timeavailable for makeup for leakage events:"The requirements for Safety Classification were compared to the requirementsspecified in 10 CFR 50.2. The criteria in the definition no longer apply. The systemsare not necessary to: (1) maintain the integrity of the Reactor Coolant System, (2) arenot required to assure the capability to shut down the reactor or maintain it in a safe-shutdown condition; or (3) are not required to mitigate the consequences of accidentswhich could result in potential offsite exposures comparable to the applicable guidelineexposures set forth in 50.34(a)(1) or 100.11 of this chapter. This is based on the factthat the SONGS Unit 2 and 3 fuel has been cooling for more than three years and 10months and the cooling load has been reduced by more than ninety percent. Thesignificantly reduced heat load has resulted in at least four days to reach 200 degreesF with no actions taken and approximately a week to reach boiling (Reference 10).This is a dramatic change from normal plant operation in which the SFP would havereached 200 degrees in a matter of a few hours. While the lower decay heat moredirectly applies to a loss of cooling: a loss of level similarly has a longer responsetime The calculations performed and reviewed by the NRC Staff to support the PostNovember 19, 2015 Defueled Emergency Plan (PDEP) demonstrate that even beyond design basiscatastrophic losses of inventory can be readily mitigated prior to exceeding establishedthresholds. The Safety Evaluation for the PDEP LAR states in part: "The NRC stafffinds that the licensee's planned SFP cooling and makeup water availability conformsto the capabilities assumed for the NRC staffs analysis presented in NUREG-1 738(Reference 11)." Thus the Augmented Quality classification was consideredappropriate for the SEP Cooling and Makeup systems.SCE is currently modifying the facility to establish a Seismic Category I source andmechanical system by upgrading the SFP Makeup System (which provides makeupfrom the Seismic Primary Water Storage Tanks). Procedure SO23-V-5.100 "SONGSMitigating Strategies" (Reference 9) provides several methods of providing SFPMakeup which can be accomplished with minimum staffing, procedures andequipment on-site in a matter of hours (Reference 12).B. Provide a diagram of the spent fuel handling building identifying: 1) the location of thepools; 2) the location of permanent makeup lines; 3) the location of standpipe connectionsthat could be used for makeup; and, 4) the path(s) designated within the fuel handlingbuilding for SFP makeup water addition using hoses from the various alternate makeupsources.SONGS ResponseAttachment 1 includes sketches depicting the requested information and relatedpictures of key equipment and staged resources for illustration.The SEP Makeup Modification currently being installed also adds a connection fromthe Fire System to the Makeup injection line which eliminates the need to enter thepool operating floor to access the hose cabinets. It also provides an additional nozzleoutside the Fuel handling Building on the east road that will enable outside sources ofwater to enter the makeup injection line without staging any internal hoses oraccessing the pool operating floor.C. Considering the large number of potential makeup sources reliant on the decommissioningQuality Class Ill electric electrical distribution system, explain the extent of testing andpreventive maintenance that would be applicable to the identified engine-driven andgravity makeup sources (i.e., the diesel fire water pump, sources identified for mitigatingstrategies, and the portable fire water pump).SONGS ResponseSONGS Procedure SO23-3-3.36 describes Fire Suppression system testingincluding Electric Fire Pumps, Diesel Fire Pumps and Fire Water Flow-paths(Reference 13). SONGS Procedure SO23-1-2.18 describes periodic testing of theDiesel. Fire Pump Batteries (Reference 14). These pumps can be used to delivermakeup water from a variety of sources, including the Demineralized Water StorageTanks located at a higher elevation on the south side of the plant. Attachment 2Contains a summary of the testing performed on the pumps and associatedMitigating Strategy Equipment.November 19, 2015 RAI-SBPB -02: Attached SystemsSystems connected to the spent fuei pool, such as the cooling and permanent make-up wateraddition systems, may contribute to inadvertent drainage. Section 9.1.3 of the SONGS UpdatedFinal Safety Analysis Report described that anti-siphon devices and check valves providedprotection against inadvertent drainage, and these features are within the scope of SONGSTechnical Specification 4.3.2, "Drainage." The enclosure to SCE's amendment request statesthat related fuel pool structural components remain safety-related, Seismic Category I, but thefuel pool cooling system is described as Seismic Category Ill and quality Class Ill or Class Ill AQ.Clarify the seismic design and quality class specifications for the portions of the cooling andmakeup systems directly connected to the spent fuel pool that have a function to limit inadvertentor accidental drainage. Also, clarify the scope of quality assurance measures that will bemaintained for equipment with the Quality Class Ill AQ designation.SONGS ResponseClarify the seismic design and quality class specifications for the portions of the cooling andmakeup systems directly connected to the spent fuel pool that have a function to limit inadvertentor accidental drainage.The Fuel Handling Building and SFP liner, transfer tube including the valve (110) andthe new Fuel pool drain valve (109- locked closed) are "Quality Class II and SeismicCategory I (Reference 15).The proposed Independent SFP Cooling System discharges through the Spent FuelPool Cooling System discharge line, which has existing siphon protectionThe proposed Independent SFP Cooling System independently takes suction from theSpent Fuel Transfer Pool through a pipe that extends from the operating floor down tothe same elevation as the existing Spent Fuel Pool Cooling Suction Line.For elevation details, please refer to Attachment 3 "Spent Fuel Pool Level CorrelationChart,7 which is a reproduction of the applicable portions of Attachment 7 to Reference16. It relates various alarm and equipment elevations to the Technical Specificationlimits above stored fuel and standard plant elevations for ease in locating the variousvalues and completeness.SONGS ResponseAlso, clarify the scope of quality assurance measures that will be maintained for equipment withthe Quality Class Ill AQ designation.The SONGS Q-List (90034) is currently located in Appendix 3.2A of the UFSAR. Table 1(included as Attachment 4) is a list of the 10 CFR 50 Appendix B Criteria applied tostructures, system and components designated as AQ (Augmented Quality). There arefour general categories of AQ equipment (fire, security, radiation monitors and Spent FuelPool Cooling and Make-up (Column D). Thirteen of the eighteen Appendix B Criteria applyto the extent noted. Those indicated as N/A should be understood to not require fullN'ovemnber 19, 2015 Appendix B controls. However, more appropriate criteria are established andimplemented.RAI-SBPB -03: Island Spent Fuel Pool Cooling SystemClarify how the drainage prevention requirement of Technical Specification 4.3.2 will be satisfiedby the ISFPCS. Specifically, either describe that the system is not connected to any piping thatextends to within 23 feet of the top of the stored fuel or provide a drawing and describe how anyleakage from the primary loop would be returned to the spent fuel pool.SONGS Response:SONGS Defueled Technical Specification 4.3.2 States: 'The spent fuel storage pool isdesigned and shall be maintained to prevent inadvertent draining of the pool belowTechnical Specification 3.1.1 value (23 feet above the top of irradiated fuel assembliesseated in the storage racks)" (Reference 17). The system is not connected to any pipingthat extends to within 23 feet of the top of the stored fuel other than the discharge linewhich includes an appropriate siphon break. As noted in the response to RAI-SBPB-02the suction lines are independent but are slightly (<1 foot) below the TechnicalSpecification level to support cooling throughout the allowed range.No changes are being made to the Fuel Handling building or interconnected piping belowthe Technical Specification water level. As described above, procedures are in place forOperations to monitor level, pressure, and temperature of the SEP. Procedures are inplace to operate and maintain the existing SEP Cooling equipment as well as the proposedIndependent SFP Cooling System equipment. Procedures are in place to utilize severalalternative methods of providing SEP Makeup using the Fire Protection System, Service(city) Water System, DWST tank located in the North Industrial Area (NIA), MakeupDemineralizer Tanks in the South yard, and connections for Fire Department sources.November 19, 2015

REFERENCES:

1. SONGS Unit 2 and 3 UFSAR as Updated, Section 9.1.4.1.3.1.E,2. SONGS Calculation C-259-01 .02.07, Revision 2, Sheet 17 of 39 (Cask Calculation)3. SONGS Unit 2 and 3 UFSAR as Updated, Section 9.1 .4.3.2.G4. SONGS Unit 2 and 3 UFSAR as Updated, Section 9.1.2.2 & 3 (Control of Leakage)5. SONGS Station Procedure SO23-3-2.11 Revision 43, Section 6 and Attachment 15, andAttachment 216. SONGS Unit 2 and 3 UFSAR as Updated, Section 15.7.3.4, 5, 6, and 77. SONGS Station Procedure SO23-13-23 Revision 18, Section 28. SONGS Station Procedure SO23-13-20 Revision 149. SONGS Station Procedure SO23-V-5.100 Revision 14,10. SONGS calculation N-0220-037, Spent Fuel Pool Time to Boil11. NRC Letter dated 06/04/15, SONGS Unit 1,2,3, and ISFSI, Exemptions from certainEmergency Planning Requirements (Safety Evaluation Sections 3.1.5, 3.2.1, & 3.2.1.1)12. SONGS Emergency Response Organization On-Shift Staffing Analysis for MitigatingStrategies for Catastrophic Loss of Spent Fuel Pool Water Inventory, Revision 1, March201513. SONGS Station Procedure SO23-3-3.36 "Fire Suppression System Tests", Revision 3814. SONGS Station Procedure SO23-1-2.18, Surveillance Requirement Weekly Diesel FirePump Battery Inspection, Revision 1915. SONGS Unit 2 and 3 UFSAR as updated, Appendix 3A, "90034, Section 9.1.2 and 9.1.416. SONGS Station Procedure SO23-3-2.11.1, Revision 26, "SFP Level Change andPurification Crosstie Operations"17. SONGS Defueled Technical Specification 4.3.2November 19, 2015 ATTACHMENT 1SUPPORTING SKETCH AND PICTURESNovember 19, 201.5 SONGS FUEL HANDLING BUILDINGSFP Makeup Entersthe SFP through theexisting SFP CoolingUNIT 3 OUTAGE LAYDOWN AREA MAPSzCC-C'CC-e zCSPENT FUEL POOL MAKEUP SCHEMATICSketch 1 -SFP Normal Makeup Using P0151 ~October 28, 2015 4pmo SONGS PHOTOGRAPHS Related TO SFPMU AND POWER1500 KW Standby Generator -Base1500 KW Standby Generator -BaseNtUvembcr 19, 201 5 1500 KW Standby GeneratorNew Spray Headers above SFPNou~cmbcr 19. 2015 Spray Nozzle for alternate SFP MakeupEquipment for SFP Alternate MakeupNovemiber I 9. 2015 Fire Riser just outside SFP (Elev 63'-6")Fire Riser just inside of the door(to the outside at Elev 37")Noxcrnhci 19, 2015 ATTACHMENT 2MITIGATING STRATEGY EQUIPMENT TESTING ANDPREVENTIVE MAINTENANCENovember 19, 2015 MITIGATING STRATEGY EQUIPMENT TESTING AND PREVENTIVE MAINTENANCEDiesel Driven Firewater Pump SA2301 MP220Description Frequency ProcedureMonthly Operability Verification 31 days 5023-3-36, Fire SuppressionTestsAnnual Operability Verification 12 months SO23-3-36.1, Fire SuppresshAnnual TestsManufacture's Preventative Maintenance 18 months SO23-1-2.21, Surveillance DitFirewater PumpSSystemon Systemesel DrivenElectric Driven Firewater Pumps SA2301 MP221 and 222Description FrequencyMonthly Operability Verification 31 daysAnnual Operability Verification 12 monthsFlow path Verification 3 yearsFirewater Storage Tanks SA2301 MT102/103DescriptionWater Supply VerificationInternal/External InspectionFrequency7 days5 yearsProcedureS023-3-365023-3-36.1SO23-X111-40ProcedureSO23-3-3.27.3SONGS Maintenance Plan 30019492ProcedureSO23-XV-4.67SO23-XV-4.67SO23-XV-4.67Seismically Qualified Diesel Driven Pump SA2301 MP1065Description FrequencyMonthly Operability Verification 31 daysAnnual Operability Verification 12 monthsManufacture's Preventative Maintenance 18 monthsNovember 19, 2015 Gasoline Driven Skid Mounted Makeup Pump SA2301 MP1058Description Frequency ProcedureMonthly Operability Verification 31 days SO23-XIII-73Annual Operability Verification 12 months SO23-XlIl-73tManufacture's Preventative Maintenance 12 months SO23-X111-73Seismically Qualified Water Storage Tank SA1417 MT351Description FrequencyWater Supply Verification 7 daysProcedureS023-3-3.27.3Demineralized Water Storage Tanks SA1417 MT266/267/268Description Frequency ProcedureWater Supply Verification 7 days SO23-3-3.27.3Fire Hoses Credited for Mitigation Strategies UseDescription Frequency Procedure_Visual Verification 4 months SO23-X111-56Hydrostatic Testing 12 months SO23-X111-44Fire Hose Stations and Standpipes Credited for Mitigation Strategies UseDescription Frequency ProcedureVisual Verification 4 months SO23-X111-56, SO23-X111-56Standpipe Testing 12 months SO23-X111-56, SO23-XI11-56November 19, 2015 ATTACHMENT 3SPENT FUEL POOL LEVEL CORRELATIONNovember 19, 201.5 SPENT FUEL POOL LEVEL CORRELATION CHARTHEIGHTPLNSFP LEVEL REFERENCE ABOVE FUELELVTOIN RACKSSEP Overflow 28' 5 1/2"' 61' 5"High Level Alarm Setpoint 28' 3"(Control Room Indicator Upper Limit) (CR Ind. 28' 2 9/16") 612/"Normal Low Alarm Setpoint 26' 6 1/2" 59' 6"Unit 3 SEP Cooling Discharge 26' 0 1/2" 59' 0"Siphon BreakUnit 2 SEP Cooling Discharge 25' 11 1/2" 58' 11"Siphon BreakPurification Low Suction Limit 23' 2 1/2" 56' 2"LCO Limit [CTS] 3.7.16 [PDTSJ 3.1.1 2'0 6Control Room Indication Lower Limit 22' 0" 55'SEP Suction (piping center line) 21' 10 1/2" 54' 10"Bottom of Transfer Pool Refueling Gate 2' 5 1/2" 35' 5"Top of Fuel Assemblies 0' 0" 33'N4ovember 19. 2015 ATTACHMENT 4TABLE 1 OF Q-LISTAPPENDIX B APPLICABILITY TO AUGMENTEDQUALITY SSCsN'ovemnber 19, 2015 TABLE 1 -APPENDIX B APPLICABILITY TO AUGMENTED QUALITY SSCsA B C D E FApp B Fire QCIII-AQ SFP QCIII-AQ NuclearCriteria Description Protection Cooling & RadiationMakeup (1) Monitors(2) Security(3)1 Organization NA NA NA NA2 Quality Assurance Program A* A* A* A*3 Design Control A* A* A* A*Procurement DocumentCotrlA* A A A*5 Instructions, Procedures, A* A A ADrawings________6 Document Control A A A AControl of Purchased7 Material, Equipment, & A* A A A*ServicesIdentification and Control8of Materials, Parts, and NA NA NA NAcomponents9Control of Special NA A NA NAProcesses10 Inspection A* A -NA NA11 Test Control A* NA NA A12 Control of M&TE NA A A A13 Handling, Storage, & NA NA NA NAShipping ________14 Inspection, Test, and A* NA NA AOperating Status_______15 Nonconforming Materials, A* A A NA16 Corrective Action A* A A A17 Quality Assurance Records A* A A A18 Audits A A A AKey:A = Applicable. The correlating chapter of the DQAP applies in its entirety.NA =Not Applicable. The correlating chapter of the DQAP does not apply.A* = Applicable with comments as delineated in Applicability Comments below.Notes:(1) SFP cooling refers to those QCIII-AQ SSCs that su~pport SFP cooling, including CCW and SWC(2) The specific monitors that are QCTII-AQ are listed in Note bb at the end of the Q-list.(3) Nuclear Security SSCs include those SSCs described in Note (as) in the NOTES section of this document.Applicability Comments:NOTE: A letter followed by a number refers to the position in Table 1. For example, C3 refers to Fire Protection,App B Criterion 3, Design ControlNovember 19, 2015 Generic:C2, D2, E2, F2 (QAP) QA Program requirements are limited as defined in this table.C3, D3, E3, F3 (Design Control): Because in the decommissioned state the original design requirements may beoverly cumbersome and no longer applicable, the following requirements of the DQAIP Section 3 do NOT apply:Where a test program is used to verify the adequacy of a specific design feature in lieu of other verifyingor checking processes, it shall include suitable qualifications testing of a prototype unit under the most adversedesign conditions.These (design) changes shall be subject to design control measures commensurate with those applied to theoriginal design.Fire Protection:C4, C5, C7, Cl0, C11, C14-C17 are applicable only to those areas where a fire hazard has the potential to adverselyaffect the function of important to safety SSCs.Nuclear Security SSCsF4F7Services provided by Vendors and Contractors are required to meet Regulatory requirements listed in 10CFR 73.26, 10 CRF 73.54, 10 CFR 73.55(a) and (b), 10 CFR 73.56.ClassificationThe Equipment Classification Table provides the quality classification of major plant structures, components, andsystems. For Quality Class I and II items, the applicable requirements of 10OCFR50, Appendix B, Quality AssuranceCriteria for Nuclear Power Plants and Fuel Reprocessing Plants, have been met to ensure the highest qualitystandards.Those items designed as Quality Classes I, II, Til and TV make up the Project Q-List used in development, review,approval and control of the design of major plant structures, components, and systems. Quality classificationinformation to a finer level of detail than that provided in the Q-List may be found in approved design documents.Such approved design documents include, but are not limited to, drawings (i.e., piping and instrument diagrams,electrical elementaries, one-line diagrams, etc.), specifications, engineering evaluations, validated data bases (i.e.,mechanical consolidated database, consolidated controls database instrument index, electrical consolidated database(including environmental qualification master list), piping material classification, etc.) or as established within aComponent Classification Evaluation Document (CCED) or Technical Evaluation (TE).The Quality Class of S SCs is shown in a large number of documents and computer applications at SONGS. In thepermanently defueled condition, it is neither practical nor necessary to change all of these documents. In cases ofconflict, 90034 (Q-List) is the defining document.November 19, 2015 I SOUHERNCALIFORNIAAn EDISON, INTERNATIONAL'g CompanyJames A. KayManager, Nuclear RegulatoryAffairsNovember 19, 201510 CFR 50.90U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, D.C. 20555-0001

Subject:

Docket Nos. 50-361 and 50-362Response to a Request for Additional Information regardingAmendment Applications 270 and 255Proposed Changes to Specific Regulatory Guide Commitments SanOnofre Nuclear Generating Station, Units 2 and 3

References:

1)Letter from T. J. Palmisano (SCE) to the U. S. Nuclear RegulatoryCommission (NRC) dated August 20, 2015;

Subject:

Docket Nos. 50-361 and 50-362, Amendment Applications 270 and 255, ProposedChanges to Specific Regulatory Guide Commitments, San OnofreNuclear Generating Station, Units 2 and 3 (ADAMS Accession No.ML1 5236A018)2) Letter from M. Vaaler (NRC) to the T. J. Palmisano (SCE) datedNovember 12, 2015;

Subject:

San Onofre Nuclear GeneratingStation, Units 2 and 3 -Request for Additional Information Regardingthe License Amendment Request to Make Changes to. SpecificRegulatory Guide Commitments Related to the Implementation of"Cold and Dark" Status (ADAMS Accession No. ML15314A321.)

Dear Sir or Madam:

By letter dated August 20, 2015 (Reference 1), Southern California Edison (SCE) submitted aLicense Amendment Request (LAR), consisting of Amendment Applications Nos. 270 and 255,to Facility Operating License Numbers NPF-10 and NPF-15 for San Onofre Nuclear GeneratingStation (SONGS) Units 2 and 3, respectively. The LAR proposed to revise the Updated FinalSafety Analysis Report (UFSAR) to revise specific Regulatory Guide commitments.By letter dated November 12, 2015 (Reference 2), the NRC provided a Request for AdditionalInformation (RAI) regarding Reference 1. The response to the RAI is contained in theenclosure to this letter.AoOF?P. 0. Box 128San Clemente, CA 92672 Document Control Desk-2Noebr1,05-2-.November 19, 2015The additional information provided in the enclosure does not affect the conclusions ofthe No Significant Hazards Consideration or the Environmental Consideration providedin Reference 1.There are no new regulatory commitments in this letter or the Enclosure.If you have any questions or require any additional information, please contact me at(949) 368-7418.Sincerely,

Enclosure:

Response to NRC Request for Additional Informationcc: M. L. Dapas, Regional Administrator, NRC Region IVM. G. Vaaler, NRC Project Manager, SONGS Units 2 & 3S. Y. Hsu, California Department of Public Health, Radiologic Health Branch2 SONGS SPENT FUEL POOL ISLAND LARDRAFT RAI RESPONSESNovember 19, 2015 RAI-SBPB -01: Makeup Water for Leakage EventsA. Describe how leakage through the spent fuel pool liner resulting from the design basiscask drop and light load handling accidents would be managed. Address the actionsspecified in procedures to reduce or eliminate leakage through the leak collectionsystem and the resulting time available to provide makeup water. Provide justificationfor the quality classification of the makeup sources based on the time available formakeup for leakage events.SONGS Response"Describe how leakage through the spent fuel pool liner resulting from the design basiscask drop and light load handling accidents would be managed:"The cask loading area of the pool was designed for a cask drop, and calculationsconclude that the liner would not be penetrated (Reference 2 and 6). The SONGSUFSAR (Section 9.1.2.2) states in part that "The cask loading area of the Spent FuelStorage Pool is designed to withstand the impact loading of a dropped fuel shippingcask from a maximum height of 28 feet 6 inches".The SONGS UFSAR also notes that "Control of liquid leakage from SFP is maintainedby a system of leak chases which are placed behind the spent fuel pool liner plates.The leak chases are connected to drain lines that terminate in the leak detection sump.Observance of leakage from a drain line will allow identification of the general locationof the leakD (Reference 4).Analyzing the cask handling area for potential drops is appropriate even though theCask Handling Crane was upgraded to a 'Single Failure Proof' design (Reference 1).While the crane is Single Failure Proof, the transfer cask containing the multi-purposecanister could be postulated to drop when they are placed on the upper shelf of a caskpool for lifting yoke change-out. Yoke change-out is required because of the verticalclearance differences. During this evolution, the transfer cask and canister are notfully restrained and are postulated to fall back into the lower portion of the cask pool ifan earthquake occurs or it is otherwise tipped back into the pool area.The new fuel and spent fuel storage areas are not exposed to overhead handling ofthe spent fuel cask (Reference 3).SONGS Procedure S023-3-2-11, "Spent Fuel Pool Operations" providesrequirements for handling of loads over the Spent Fuel Pool (Reference 5), and loaddrop accidents were evaluated in the UFSAR Chapter 15 (Reference 6). Substantialprecautions are in place to preclude drops and leaks (including but not limited to safe-load paths, lift height limits, and other administrate and physical barriers). If leakageoccurs the leak chase drains would be monitored to locate the leak. SFP makeupwould be initiated using the existing installed system or any available mitigatingstrategy flow paths."Address the actions specified in procedures to reduce or eliminate leakage through theleak collection system and the resulting time available to provide mnakeup water:."November 19, 2015 Any leaks (from corrosion or other causes) into a leak chase would be limited toapproximately 50 gpm based on their cross-sectional area. Such leaks would beexpected to start much slower and be detected well before reaching even that flowrate, which is well-within SFP make-up capability. Finally, such small leaks can bemitigated by shutting the leak chase drain valves if and when it was appropriate to doSO.SONGS procedure SO23-3-2.11 governs the normal operation of the Spent Fuel Pool(SFP). Attachment 21 provides 'REQUIREMENTS' for monitoring SFP temperature,level, and limiting loads over the SFP racks (Reference 5). If REQUIREMENTS arenot met, then, Operations suspends all activities involving SFP decay heat load, ANDmonitors temperatures, AND initiates actions to restore the components. If a leak isidentified in the Cask Pool area, there is an isolation gate that can be slid into placeand its inflatable seal pressurized in accordance with Attachments 8 or 9.SONGS Procedure SO23-13-23, "Loss of Spent Fuel Pool Cooling" includes thepotential event of "Loss of SFP Inventory" (Reference 7). Should SFP level drop,Section 2 provides actions and 'actions if response not obtained.' These includeplacing any suspended fuel assembly in a safe position, suspending all fuel movement,initiating SO23-13-20, "Abnormal Operating Instruction, Fuel Handling Accidents orLoss of SFP Level Control" (Reference 8), verifying siphon breaker is covered, andmonitoring/restoring boron concentration. Exit conditions from this procedure are SEPLevel > 23', SEP cooling restored, SEP temperature <140 Degrees F and stable, andpowered from Offsite Power (Exit Conditions Section).SONGS SO23-13-20 "Abnormal Operating Instruction, Fuel Handling Accidents orLoss of SEP Level Control" (Reference 8) specifies similar corrective actions for lossof level.SONGS SO23-V-5.100 "Songs Mitigating Strategies" (Reference 9) provides multipleoptions for providing SFP Makeup, depending on the circumstances that resulted inentering the procedure (i.e., Fire, Security issue, mechanical loss of inventory, etc.)."Provide justification for the quality classification of the makeup sources based on the timeavailable for makeup for leakage events:"The requirements for Safety Classification were compared to the requirementsspecified in 10 CFR 50.2. The criteria in the definition no longer apply. The systemsare not necessary to: (1) maintain the integrity of the Reactor Coolant System, (2) arenot required to assure the capability to shut down the reactor or maintain it in a safe-shutdown condition; or (3) are not required to mitigate the consequences of accidentswhich could result in potential offsite exposures comparable to the applicable guidelineexposures set forth in 50.34(a)(1) or 100.11 of this chapter. This is based on the factthat the SONGS Unit 2 and 3 fuel has been cooling for more than three years and 10months and the cooling load has been reduced by more than ninety percent. Thesignificantly reduced heat load has resulted in at least four days to reach 200 degreesF with no actions taken and approximately a week to reach boiling (Reference 10).This is a dramatic change from normal plant operation in which the SFP would havereached 200 degrees in a matter of a few hours. While the lower decay heat moredirectly applies to a loss of cooling: a loss of level similarly has a longer responsetime The calculations performed and reviewed by the NRC Staff to support the PostNovember 19, 2015 Defueled Emergency Plan (PDEP) demonstrate that even beyond design basiscatastrophic losses of inventory can be readily mitigated prior to exceeding establishedthresholds. The Safety Evaluation for the PDEP LAR states in part: "The NRC stafffinds that the licensee's planned SFP cooling and makeup water availability conformsto the capabilities assumed for the NRC staffs analysis presented in NUREG-1 738(Reference 11)." Thus the Augmented Quality classification was consideredappropriate for the SEP Cooling and Makeup systems.SCE is currently modifying the facility to establish a Seismic Category I source andmechanical system by upgrading the SFP Makeup System (which provides makeupfrom the Seismic Primary Water Storage Tanks). Procedure SO23-V-5.100 "SONGSMitigating Strategies" (Reference 9) provides several methods of providing SFPMakeup which can be accomplished with minimum staffing, procedures andequipment on-site in a matter of hours (Reference 12).B. Provide a diagram of the spent fuel handling building identifying: 1) the location of thepools; 2) the location of permanent makeup lines; 3) the location of standpipe connectionsthat could be used for makeup; and, 4) the path(s) designated within the fuel handlingbuilding for SFP makeup water addition using hoses from the various alternate makeupsources.SONGS ResponseAttachment 1 includes sketches depicting the requested information and relatedpictures of key equipment and staged resources for illustration.The SEP Makeup Modification currently being installed also adds a connection fromthe Fire System to the Makeup injection line which eliminates the need to enter thepool operating floor to access the hose cabinets. It also provides an additional nozzleoutside the Fuel handling Building on the east road that will enable outside sources ofwater to enter the makeup injection line without staging any internal hoses oraccessing the pool operating floor.C. Considering the large number of potential makeup sources reliant on the decommissioningQuality Class Ill electric electrical distribution system, explain the extent of testing andpreventive maintenance that would be applicable to the identified engine-driven andgravity makeup sources (i.e., the diesel fire water pump, sources identified for mitigatingstrategies, and the portable fire water pump).SONGS ResponseSONGS Procedure SO23-3-3.36 describes Fire Suppression system testingincluding Electric Fire Pumps, Diesel Fire Pumps and Fire Water Flow-paths(Reference 13). SONGS Procedure SO23-1-2.18 describes periodic testing of theDiesel. Fire Pump Batteries (Reference 14). These pumps can be used to delivermakeup water from a variety of sources, including the Demineralized Water StorageTanks located at a higher elevation on the south side of the plant. Attachment 2Contains a summary of the testing performed on the pumps and associatedMitigating Strategy Equipment.November 19, 2015 RAI-SBPB -02: Attached SystemsSystems connected to the spent fuei pool, such as the cooling and permanent make-up wateraddition systems, may contribute to inadvertent drainage. Section 9.1.3 of the SONGS UpdatedFinal Safety Analysis Report described that anti-siphon devices and check valves providedprotection against inadvertent drainage, and these features are within the scope of SONGSTechnical Specification 4.3.2, "Drainage." The enclosure to SCE's amendment request statesthat related fuel pool structural components remain safety-related, Seismic Category I, but thefuel pool cooling system is described as Seismic Category Ill and quality Class Ill or Class Ill AQ.Clarify the seismic design and quality class specifications for the portions of the cooling andmakeup systems directly connected to the spent fuel pool that have a function to limit inadvertentor accidental drainage. Also, clarify the scope of quality assurance measures that will bemaintained for equipment with the Quality Class Ill AQ designation.SONGS ResponseClarify the seismic design and quality class specifications for the portions of the cooling andmakeup systems directly connected to the spent fuel pool that have a function to limit inadvertentor accidental drainage.The Fuel Handling Building and SFP liner, transfer tube including the valve (110) andthe new Fuel pool drain valve (109- locked closed) are "Quality Class II and SeismicCategory I (Reference 15).The proposed Independent SFP Cooling System discharges through the Spent FuelPool Cooling System discharge line, which has existing siphon protectionThe proposed Independent SFP Cooling System independently takes suction from theSpent Fuel Transfer Pool through a pipe that extends from the operating floor down tothe same elevation as the existing Spent Fuel Pool Cooling Suction Line.For elevation details, please refer to Attachment 3 "Spent Fuel Pool Level CorrelationChart,7 which is a reproduction of the applicable portions of Attachment 7 to Reference16. It relates various alarm and equipment elevations to the Technical Specificationlimits above stored fuel and standard plant elevations for ease in locating the variousvalues and completeness.SONGS ResponseAlso, clarify the scope of quality assurance measures that will be maintained for equipment withthe Quality Class Ill AQ designation.The SONGS Q-List (90034) is currently located in Appendix 3.2A of the UFSAR. Table 1(included as Attachment 4) is a list of the 10 CFR 50 Appendix B Criteria applied tostructures, system and components designated as AQ (Augmented Quality). There arefour general categories of AQ equipment (fire, security, radiation monitors and Spent FuelPool Cooling and Make-up (Column D). Thirteen of the eighteen Appendix B Criteria applyto the extent noted. Those indicated as N/A should be understood to not require fullN'ovemnber 19, 2015 Appendix B controls. However, more appropriate criteria are established andimplemented.RAI-SBPB -03: Island Spent Fuel Pool Cooling SystemClarify how the drainage prevention requirement of Technical Specification 4.3.2 will be satisfiedby the ISFPCS. Specifically, either describe that the system is not connected to any piping thatextends to within 23 feet of the top of the stored fuel or provide a drawing and describe how anyleakage from the primary loop would be returned to the spent fuel pool.SONGS Response:SONGS Defueled Technical Specification 4.3.2 States: 'The spent fuel storage pool isdesigned and shall be maintained to prevent inadvertent draining of the pool belowTechnical Specification 3.1.1 value (23 feet above the top of irradiated fuel assembliesseated in the storage racks)" (Reference 17). The system is not connected to any pipingthat extends to within 23 feet of the top of the stored fuel other than the discharge linewhich includes an appropriate siphon break. As noted in the response to RAI-SBPB-02the suction lines are independent but are slightly (<1 foot) below the TechnicalSpecification level to support cooling throughout the allowed range.No changes are being made to the Fuel Handling building or interconnected piping belowthe Technical Specification water level. As described above, procedures are in place forOperations to monitor level, pressure, and temperature of the SEP. Procedures are inplace to operate and maintain the existing SEP Cooling equipment as well as the proposedIndependent SFP Cooling System equipment. Procedures are in place to utilize severalalternative methods of providing SEP Makeup using the Fire Protection System, Service(city) Water System, DWST tank located in the North Industrial Area (NIA), MakeupDemineralizer Tanks in the South yard, and connections for Fire Department sources.November 19, 2015

REFERENCES:

1. SONGS Unit 2 and 3 UFSAR as Updated, Section 9.1.4.1.3.1.E,2. SONGS Calculation C-259-01 .02.07, Revision 2, Sheet 17 of 39 (Cask Calculation)3. SONGS Unit 2 and 3 UFSAR as Updated, Section 9.1 .4.3.2.G4. SONGS Unit 2 and 3 UFSAR as Updated, Section 9.1.2.2 & 3 (Control of Leakage)5. SONGS Station Procedure SO23-3-2.11 Revision 43, Section 6 and Attachment 15, andAttachment 216. SONGS Unit 2 and 3 UFSAR as Updated, Section 15.7.3.4, 5, 6, and 77. SONGS Station Procedure SO23-13-23 Revision 18, Section 28. SONGS Station Procedure SO23-13-20 Revision 149. SONGS Station Procedure SO23-V-5.100 Revision 14,10. SONGS calculation N-0220-037, Spent Fuel Pool Time to Boil11. NRC Letter dated 06/04/15, SONGS Unit 1,2,3, and ISFSI, Exemptions from certainEmergency Planning Requirements (Safety Evaluation Sections 3.1.5, 3.2.1, & 3.2.1.1)12. SONGS Emergency Response Organization On-Shift Staffing Analysis for MitigatingStrategies for Catastrophic Loss of Spent Fuel Pool Water Inventory, Revision 1, March201513. SONGS Station Procedure SO23-3-3.36 "Fire Suppression System Tests", Revision 3814. SONGS Station Procedure SO23-1-2.18, Surveillance Requirement Weekly Diesel FirePump Battery Inspection, Revision 1915. SONGS Unit 2 and 3 UFSAR as updated, Appendix 3A, "90034, Section 9.1.2 and 9.1.416. SONGS Station Procedure SO23-3-2.11.1, Revision 26, "SFP Level Change andPurification Crosstie Operations"17. SONGS Defueled Technical Specification 4.3.2November 19, 2015 ATTACHMENT 1SUPPORTING SKETCH AND PICTURESNovember 19, 201.5 SONGS FUEL HANDLING BUILDINGSFP Makeup Entersthe SFP through theexisting SFP CoolingUNIT 3 OUTAGE LAYDOWN AREA MAPSzCC-C'CC-e zCSPENT FUEL POOL MAKEUP SCHEMATICSketch 1 -SFP Normal Makeup Using P0151 ~October 28, 2015 4pmo SONGS PHOTOGRAPHS Related TO SFPMU AND POWER1500 KW Standby Generator -Base1500 KW Standby Generator -BaseNtUvembcr 19, 201 5 1500 KW Standby GeneratorNew Spray Headers above SFPNou~cmbcr 19. 2015 Spray Nozzle for alternate SFP MakeupEquipment for SFP Alternate MakeupNovemiber I 9. 2015 Fire Riser just outside SFP (Elev 63'-6")Fire Riser just inside of the door(to the outside at Elev 37")Noxcrnhci 19, 2015 ATTACHMENT 2MITIGATING STRATEGY EQUIPMENT TESTING ANDPREVENTIVE MAINTENANCENovember 19, 2015 MITIGATING STRATEGY EQUIPMENT TESTING AND PREVENTIVE MAINTENANCEDiesel Driven Firewater Pump SA2301 MP220Description Frequency ProcedureMonthly Operability Verification 31 days 5023-3-36, Fire SuppressionTestsAnnual Operability Verification 12 months SO23-3-36.1, Fire SuppresshAnnual TestsManufacture's Preventative Maintenance 18 months SO23-1-2.21, Surveillance DitFirewater PumpSSystemon Systemesel DrivenElectric Driven Firewater Pumps SA2301 MP221 and 222Description FrequencyMonthly Operability Verification 31 daysAnnual Operability Verification 12 monthsFlow path Verification 3 yearsFirewater Storage Tanks SA2301 MT102/103DescriptionWater Supply VerificationInternal/External InspectionFrequency7 days5 yearsProcedureS023-3-365023-3-36.1SO23-X111-40ProcedureSO23-3-3.27.3SONGS Maintenance Plan 30019492ProcedureSO23-XV-4.67SO23-XV-4.67SO23-XV-4.67Seismically Qualified Diesel Driven Pump SA2301 MP1065Description FrequencyMonthly Operability Verification 31 daysAnnual Operability Verification 12 monthsManufacture's Preventative Maintenance 18 monthsNovember 19, 2015 Gasoline Driven Skid Mounted Makeup Pump SA2301 MP1058Description Frequency ProcedureMonthly Operability Verification 31 days SO23-XIII-73Annual Operability Verification 12 months SO23-XlIl-73tManufacture's Preventative Maintenance 12 months SO23-X111-73Seismically Qualified Water Storage Tank SA1417 MT351Description FrequencyWater Supply Verification 7 daysProcedureS023-3-3.27.3Demineralized Water Storage Tanks SA1417 MT266/267/268Description Frequency ProcedureWater Supply Verification 7 days SO23-3-3.27.3Fire Hoses Credited for Mitigation Strategies UseDescription Frequency Procedure_Visual Verification 4 months SO23-X111-56Hydrostatic Testing 12 months SO23-X111-44Fire Hose Stations and Standpipes Credited for Mitigation Strategies UseDescription Frequency ProcedureVisual Verification 4 months SO23-X111-56, SO23-X111-56Standpipe Testing 12 months SO23-X111-56, SO23-XI11-56November 19, 2015 ATTACHMENT 3SPENT FUEL POOL LEVEL CORRELATIONNovember 19, 201.5 SPENT FUEL POOL LEVEL CORRELATION CHARTHEIGHTPLNSFP LEVEL REFERENCE ABOVE FUELELVTOIN RACKSSEP Overflow 28' 5 1/2"' 61' 5"High Level Alarm Setpoint 28' 3"(Control Room Indicator Upper Limit) (CR Ind. 28' 2 9/16") 612/"Normal Low Alarm Setpoint 26' 6 1/2" 59' 6"Unit 3 SEP Cooling Discharge 26' 0 1/2" 59' 0"Siphon BreakUnit 2 SEP Cooling Discharge 25' 11 1/2" 58' 11"Siphon BreakPurification Low Suction Limit 23' 2 1/2" 56' 2"LCO Limit [CTS] 3.7.16 [PDTSJ 3.1.1 2'0 6Control Room Indication Lower Limit 22' 0" 55'SEP Suction (piping center line) 21' 10 1/2" 54' 10"Bottom of Transfer Pool Refueling Gate 2' 5 1/2" 35' 5"Top of Fuel Assemblies 0' 0" 33'N4ovember 19. 2015 ATTACHMENT 4TABLE 1 OF Q-LISTAPPENDIX B APPLICABILITY TO AUGMENTEDQUALITY SSCsN'ovemnber 19, 2015 TABLE 1 -APPENDIX B APPLICABILITY TO AUGMENTED QUALITY SSCsA B C D E FApp B Fire QCIII-AQ SFP QCIII-AQ NuclearCriteria Description Protection Cooling & RadiationMakeup (1) Monitors(2) Security(3)1 Organization NA NA NA NA2 Quality Assurance Program A* A* A* A*3 Design Control A* A* A* A*Procurement DocumentCotrlA* A A A*5 Instructions, Procedures, A* A A ADrawings________6 Document Control A A A AControl of Purchased7 Material, Equipment, & A* A A A*ServicesIdentification and Control8of Materials, Parts, and NA NA NA NAcomponents9Control of Special NA A NA NAProcesses10 Inspection A* A -NA NA11 Test Control A* NA NA A12 Control of M&TE NA A A A13 Handling, Storage, & NA NA NA NAShipping ________14 Inspection, Test, and A* NA NA AOperating Status_______15 Nonconforming Materials, A* A A NA16 Corrective Action A* A A A17 Quality Assurance Records A* A A A18 Audits A A A AKey:A = Applicable. The correlating chapter of the DQAP applies in its entirety.NA =Not Applicable. The correlating chapter of the DQAP does not apply.A* = Applicable with comments as delineated in Applicability Comments below.Notes:(1) SFP cooling refers to those QCIII-AQ SSCs that su~pport SFP cooling, including CCW and SWC(2) The specific monitors that are QCTII-AQ are listed in Note bb at the end of the Q-list.(3) Nuclear Security SSCs include those SSCs described in Note (as) in the NOTES section of this document.Applicability Comments:NOTE: A letter followed by a number refers to the position in Table 1. For example, C3 refers to Fire Protection,App B Criterion 3, Design ControlNovember 19, 2015 Generic:C2, D2, E2, F2 (QAP) QA Program requirements are limited as defined in this table.C3, D3, E3, F3 (Design Control): Because in the decommissioned state the original design requirements may beoverly cumbersome and no longer applicable, the following requirements of the DQAIP Section 3 do NOT apply:Where a test program is used to verify the adequacy of a specific design feature in lieu of other verifyingor checking processes, it shall include suitable qualifications testing of a prototype unit under the most adversedesign conditions.These (design) changes shall be subject to design control measures commensurate with those applied to theoriginal design.Fire Protection:C4, C5, C7, Cl0, C11, C14-C17 are applicable only to those areas where a fire hazard has the potential to adverselyaffect the function of important to safety SSCs.Nuclear Security SSCsF4F7Services provided by Vendors and Contractors are required to meet Regulatory requirements listed in 10CFR 73.26, 10 CRF 73.54, 10 CFR 73.55(a) and (b), 10 CFR 73.56.ClassificationThe Equipment Classification Table provides the quality classification of major plant structures, components, andsystems. For Quality Class I and II items, the applicable requirements of 10OCFR50, Appendix B, Quality AssuranceCriteria for Nuclear Power Plants and Fuel Reprocessing Plants, have been met to ensure the highest qualitystandards.Those items designed as Quality Classes I, II, Til and TV make up the Project Q-List used in development, review,approval and control of the design of major plant structures, components, and systems. Quality classificationinformation to a finer level of detail than that provided in the Q-List may be found in approved design documents.Such approved design documents include, but are not limited to, drawings (i.e., piping and instrument diagrams,electrical elementaries, one-line diagrams, etc.), specifications, engineering evaluations, validated data bases (i.e.,mechanical consolidated database, consolidated controls database instrument index, electrical consolidated database(including environmental qualification master list), piping material classification, etc.) or as established within aComponent Classification Evaluation Document (CCED) or Technical Evaluation (TE).The Quality Class of S SCs is shown in a large number of documents and computer applications at SONGS. In thepermanently defueled condition, it is neither practical nor necessary to change all of these documents. In cases ofconflict, 90034 (Q-List) is the defining document.November 19, 2015