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| {{#Wiki_filter:ISOUTHERN CALIFORNIA EDISON An EDISON INTERNATIONAL Company A. Edward Scherer Manager of Nuclear Regulatory Affairs November 13, 2006 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 | | {{#Wiki_filter:ISOUTHERN CALIFORNIA A. Edward Scherer EDISON Manager of Nuclear Regulatory Affairs An EDISON INTERNATIONAL Company November 13, 2006 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 |
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| ==Subject:== | | ==Subject:== |
| | Docket Nos. 50-361 and 50-362 Additional Information in Support of Amendment Application Numbers 243 and 227 (TAC Nos. MD1405 and MD1406) |
| | San Onofre Nuclear Generating Station, Units 2 and 3 |
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| ==Reference:== | | ==Reference:== |
| | | Letter from N. Kalyanam (NRC) to Richard M. Rosenblum (SCE) dated October 26, 2006; |
| Docket Nos. 50-361 and 50-362 Additional Information in Support of Amendment Application Numbers 243 and 227 (TAC Nos. MD1405 and MD1406)San Onofre Nuclear Generating Station, Units 2 and 3 Letter from N. Kalyanam (NRC) to Richard M. Rosenblum (SCE) dated October 26, 2006;
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| ==Subject:== | | ==Subject:== |
| San Onofre Nuclear Generating Station, Units 2 and 3 -Request for Additional Information on the Proposed Amendment to Revise Fuel Storage Pool Boron Concentration (TAC Nos. MD1405 and MD1406) ., | | San Onofre Nuclear Generating Station, Units 2 and 3 - |
| | Request for Additional Information on the Proposed Amendment to Revise Fuel Storage Pool Boron Concentration (TAC Nos. MD1405 and MD1406) ., |
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| ==Dear Sir or Madam:== | | ==Dear Sir or Madam:== |
| This letter responds to the October 26, 2006 U.S. Nuclear Regulatory Commission request for additional information (Reference). | | |
| The enclosure contains an answer to the first question, and a schedule to provide the answer to the second question.Should you have any questions, please contact Ms. Lynn Pressey at 949-368-6351. | | This letter responds to the October 26, 2006 U.S. Nuclear Regulatory Commission request for additional information (Reference). The enclosure contains an answer to the first question, and a schedule to provide the answer to the second question. |
| Sincerely, | | Should you have any questions, please contact Ms. Lynn Pressey at 949-368-6351. |
| | Sincerely, |
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| ==Enclosure:== | | ==Enclosure:== |
| | As stated cc: B. S. Mallett, 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 P.O. Box 128 San Clemente, CA 92672 949-368-7501 A 0 'DI Fax 949-368-7575 |
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| | Southern California Edison (SCE) |
| | San Onofre Nuclear Generating Station (SONGS), Units 2 and 3 Docket Nos. 50-361 and 50-362 Enclosure Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 556 |
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| | Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 556 NRC Question 1: |
| | Section 2.10 of the Spent Fuel Pool (SFP) Boron Dilution Analysis states that the SFP boron concentration must be verified in accordance with LCS 3.7.116 at least every 30 days. Clarify how this verification relates to Technical specification SR 3.7.17.1, which requires verification of the SFP boron concentration every 7 days. |
| | SCE Response to Question 1: |
| | Licensee Controlled Specification (LCS) 3.7.116 and Technical Specification Surveillance Requirement (SR) 3.7.17.1, have separate periods of applicability. |
| | The applicability of LCS 3.7.116 is when fuel is stored in the fuel storage pool and no fuel movement is being performed in the fuel storage pool. |
| | The applicability of (SR) 3.7.17.1 is when fuel assemblies are stored in the fuel storage pool and a fuel storage pool verification has not been performed since the last movement of fuel assemblies in the fuel storage pool. |
| | The fuel storage verification is performed after fuel is moved into, out of, or within the spent fuel pool to validate that all fuel assemblies are stored in their proper location. When fuel movement begins SCE is then required to sample boron every seven days in accordance with SR 3.7.17.1 until such time as the fuel storage validation is complete. Once the fuel storage validation is completed showing all fuel is properly stored SR 3.7.17.1 is no longer applicable and the spent fuel pool is sampled in accordance with the requirements of LCS 3.7.116. |
| | The Basis for applicability for the Limiting Condition of Operation (LCO) for TS 3.7.17.1 is that it applies whenever fuel assemblies are stored in the spent fuel pool until a complete spent fuel pool verification has been performed following the last movement of fuel assemblies in the spent fuel pool. This LCO does not apply following the verification since the verification would confirm that there are no misloaded fuel assemblies. With no further fuel assembly movements in progress, there is no potential for a misloaded fuel assembly or a dropped fuel assembly. |
| | Notwithstanding the TS and LCS applicability described above it has been SCE's practice to sample SFP boron concentration weekly. Additionally, SCE intends on deleting LCS 3.7.116 following the approval of the proposed amendment to revise the SFP boron concentration. |
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| As stated cc: B. S. Mallett, 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 P.O. Box 128 San Clemente, CA 92672 949-368-7501 Fax 949-368-7575 A 0 'DI Southern California Edison (SCE)San Onofre Nuclear Generating Station (SONGS), Units 2 and 3 Docket Nos. 50-361 and 50-362 Enclosure Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 556 Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 556 NRC Question 1: Section 2.10 of the Spent Fuel Pool (SFP) Boron Dilution Analysis states that the SFP boron concentration must be verified in accordance with LCS 3.7.116 at least every 30 days. Clarify how this verification relates to Technical specification SR 3.7.17.1, which requires verification of the SFP boron concentration every 7 days.SCE Response to Question 1: Licensee Controlled Specification (LCS) 3.7.116 and Technical Specification Surveillance Requirement (SR) 3.7.17.1, have separate periods of applicability.
| | Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 556 NRC Question 2: |
| The applicability of LCS 3.7.116 is when fuel is stored in the fuel storage pool and no fuel movement is being performed in the fuel storage pool.The applicability of (SR) 3.7.17.1 is when fuel assemblies are stored in the fuel storage pool and a fuel storage pool verification has not been performed since the last movement of fuel assemblies in the fuel storage pool.The fuel storage verification is performed after fuel is moved into, out of, or within the spent fuel pool to validate that all fuel assemblies are stored in their proper location.
| | Given the many dilution paths mentioned, describe how the 7 day surveillance interval is adequate to detect slow boron dilution events. In particular, address the case where unborated makeup is provided for a small (1 - 2 gallons per minute) leak that may be overlooked as an unusual condition and processed through radwaste or be otherwise undetected. |
| When fuel movement begins SCE is then required to sample boron every seven days in accordance with SR 3.7.17.1 until such time as the fuel storage validation is complete.
| | SCE Response to Question 2: |
| Once the fuel storage validation is completed showing all fuel is properly stored SR 3.7.17.1 is no longer applicable and the spent fuel pool is sampled in accordance with the requirements of LCS 3.7.116.The Basis for applicability for the Limiting Condition of Operation (LCO) for TS 3.7.17.1 is that it applies whenever fuel assemblies are stored in the spent fuel pool until a complete spent fuel pool verification has been performed following the last movement of fuel assemblies in the spent fuel pool. This LCO does not apply following the verification since the verification would confirm that there are no misloaded fuel assemblies.
| | SCE plans to provide the answer to this question by the end of December 2006. |
| With no further fuel assembly movements in progress, there is no potential for a misloaded fuel assembly or a dropped fuel assembly.Notwithstanding the TS and LCS applicability described above it has been SCE's practice to sample SFP boron concentration weekly. Additionally, SCE intends on deleting LCS 3.7.116 following the approval of the proposed amendment to revise the SFP boron concentration.
| | This schedule has been discussed with the NRC Project Manager and we understand it is acceptable. |
| 1 of 2 Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 556 NRC Question 2: Given the many dilution paths mentioned, describe how the 7 day surveillance interval is adequate to detect slow boron dilution events. In particular, address the case where unborated makeup is provided for a small (1 -2 gallons per minute) leak that may be overlooked as an unusual condition and processed through radwaste or be otherwise undetected.
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| SCE Response to Question 2: SCE plans to provide the answer to this question by the end of December 2006.This schedule has been discussed with the NRC Project Manager and we understand it is acceptable. | |
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MONTHYEARML0612207012006-04-28028 April 2006 Amendment Application Numbers 243 and 227, Proposed Change Number (PCN) 556 Request to Revise Fuel Storage Pool Boron Concentration Project stage: Request ML0629805852006-10-26026 October 2006 Request for Additional Information on the Proposed Amendment to Revise Fuel Storage Pool Boron Concentration Project stage: RAI ML0632104252006-11-13013 November 2006 Additional Information in Support of Amendment Application Numbers 243 and 227 Project stage: Other ML0636100422006-12-22022 December 2006 Additional Information in Support of Amendment Application Numbers 243 and 227 Project stage: Other ML0706705282007-03-16016 March 2007 Request for Additional Information on the Proposed Amendment to Revise Fuel Storage Pool Boron Concentration Project stage: RAI ML0709500412007-04-12012 April 2007 Request for Additional Information on the Proposed Amendment to Revise Fuel Storage Pool Boron Concentration Project stage: RAI ML0724004512007-04-18018 April 2007 SONGS 2 & 3 - 4/18/07 E-mail to D. Mercurio RAI Criticality Analysis & Ts/Lcs/Bases Changes - (Tacs. MD1405 and 1406) Project stage: RAI ML0724005052007-04-20020 April 2007 SONGS 2 & 3 - 4/20/07 E-mail to L. Conklin, RAI Acceptability to CEAs & Gt Inserts, Etc. (Tacs. MD1405 and 1406) Project stage: RAI ML0712203232007-05-0707 May 2007 Request for Additional Information on the Proposed Amendment to Revise Fuel Storage Pool Boron Concentration Project stage: RAI ML0715701692007-05-14014 May 2007 5/14/07 E-Mail to L. Conklin, SCE, from N. Kalyanam, NRC - San Onofre Nuclear Generating Station, Unit 2 & 3 - Request for Additional Information Project stage: RAI ML0717000972007-06-15015 June 2007 Amendment Application Numbers 243, Supplement 1 and 227, Supplement 1, Proposed Change Number (PCN) 556, Revision 1, Request to Revise Fuel Storage Pool Boron Concentration Project stage: Supplement ML0721300572007-07-27027 July 2007 Response to Request for Additional Information in Support of Amendment Application Numbers 243 and 227 Proposed Change Number 556, Rev 1 Request to Revise Fuel Storage Pool Boron Concentration Project stage: Response to RAI ML0725503042007-09-11011 September 2007 Amendment Application Numbers 243, Supplement 2 and 227, Supplement 2, Proposed Change Number (PCN) 556, Revision 2 Project stage: Supplement ML0725501752007-09-27027 September 2007 Issuance of Amendment Nos. 213 and 205 Request to Revise Fuel Storage Pool Boron Concentration Project stage: Approval ML0725501832007-09-27027 September 2007 Technical Specifications Pages, Revise Fuel Storage Pool Boron Concentration Project stage: Other ML1005504682010-03-0404 March 2010 Withdrawal of an Amendment Request Exclude the Source Range Neutron Flux Instrument Channel Preamplifier from the TS Channel Calibration Requirements Project stage: Withdrawal 2007-04-20
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Category:Letter
MONTHYEARML24240A1692024-09-18018 September 2024 Cy 2023 Summary of Decommissioning Trust Fund Status IR 07200041/20244012024-08-16016 August 2024 San Onofe Nuclear Generating Station, Security Baseline Inspection Report 07200041/2024401 IR 05000361/20240042024-08-0909 August 2024 NRC Inspection Report 05000361/2024004 and 05000362/2024004 ML24191A2472024-07-0202 July 2024 (Songs), Units 1, 2, and 3, and the Independent Spent Fuel Storage Installation - Revision to the ISFSI-Only Emergency Plan and Associated Changes to Emergency Plan Implementing Procedures ML24151A6482024-06-0303 June 2024 Changes in Reactor Decommissioning Branch Project Management Assignments for Some Decommissioning Facilities ML24141A0802024-05-15015 May 2024 (Songs), Units 1, 2 and 3 and Independent Spent Fuel Storage Installation - 2023 Annual Radiological Environmental Operating Report IR 05000361/20240022024-04-0101 April 2024 – NRC Inspection Report 050-00361/2024-002 and 050-00362/2024-002 ML24094A0642024-03-27027 March 2024 Independent Spent Fuel Storage Installation, Decommissioning Funding Status Report 2023 ML24065A0152024-02-28028 February 2024 Generation Station Units 1, 2 and 3, Annual Radioactive Effluent Release Report for Independent Spent Fuel Storage Installation 2023 ML24044A0812024-02-14014 February 2024 LTR-24-0008: NRC Response to Paul Blanch Email Safety of Spent Nuclear Fuel at SONGS ISFSI IR 05000361/20240012024-02-13013 February 2024 NRC Inspection Report 050-00361/2024-001 and 050-00362/2024-001 (1) ML24037A0542024-01-30030 January 2024 (Songs), Units 2 and 3, Submittal of Annual Corporate Financial Reports ML24022A1492024-01-17017 January 2024 Independent Spent Fuel Storage Installation, Revision 4 to the Physical Security Plan ML24017A2432024-01-15015 January 2024 LTR-24-0008 Paul Blanch, E-mails Request for Formal Response to Requests for Meeting to Discuss Safety Issues with NRC Staff 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 ML22238A0552022-08-29029 August 2022 U.S. Nuclear Regulatory Commission'S Analysis of Southern California Edison'S Decommissioning Funding Status Report for San Onofre Nuclear Generating Station, Units 1, 2, and 3 ML22234A1602022-07-31031 July 2022 Final Report Per 10 CFR Part 21, Degraded Snubber SF1154 Hydraulic Fluid Batch No. 18CLVS431 ML22207B8612022-07-26026 July 2022 NRC (Public) Inspection Report 05000361/2022003; 05000362/2022003 IR 05000361/20220032022-07-26026 July 2022 NRC Inspection Report (Public) 05000361-2022003 and 05000362-2022003 (002) IR 05000361/20220022022-05-12012 May 2022 NRC Inspection Report 05000361/2022-002 and 05000362/2022-002 ML22136A0842022-05-12012 May 2022 Independent Spent Fuel Storage Installation, 2021 Annual Radiological Environmental Operating Report 2024-09-18
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ISOUTHERN CALIFORNIA A. Edward Scherer EDISON Manager of Nuclear Regulatory Affairs An EDISON INTERNATIONAL Company November 13, 2006 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001
Subject:
Docket Nos. 50-361 and 50-362 Additional Information in Support of Amendment Application Numbers 243 and 227 (TAC Nos. MD1405 and MD1406)
San Onofre Nuclear Generating Station, Units 2 and 3
Reference:
Letter from N. Kalyanam (NRC) to Richard M. Rosenblum (SCE) dated October 26, 2006;
Subject:
San Onofre Nuclear Generating Station, Units 2 and 3 -
Request for Additional Information on the Proposed Amendment to Revise Fuel Storage Pool Boron Concentration (TAC Nos. MD1405 and MD1406) .,
Dear Sir or Madam:
This letter responds to the October 26, 2006 U.S. Nuclear Regulatory Commission request for additional information (Reference). The enclosure contains an answer to the first question, and a schedule to provide the answer to the second question.
Should you have any questions, please contact Ms. Lynn Pressey at 949-368-6351.
Sincerely,
Enclosure:
As stated cc: B. S. Mallett, 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 P.O. Box 128 San Clemente, CA 92672 949-368-7501 A 0 'DI Fax 949-368-7575
Southern California Edison (SCE)
San Onofre Nuclear Generating Station (SONGS), Units 2 and 3 Docket Nos. 50-361 and 50-362 Enclosure Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 556
Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 556 NRC Question 1:
Section 2.10 of the Spent Fuel Pool (SFP) Boron Dilution Analysis states that the SFP boron concentration must be verified in accordance with LCS 3.7.116 at least every 30 days. Clarify how this verification relates to Technical specification SR 3.7.17.1, which requires verification of the SFP boron concentration every 7 days.
SCE Response to Question 1:
Licensee Controlled Specification (LCS) 3.7.116 and Technical Specification Surveillance Requirement (SR) 3.7.17.1, have separate periods of applicability.
The applicability of LCS 3.7.116 is when fuel is stored in the fuel storage pool and no fuel movement is being performed in the fuel storage pool.
The applicability of (SR) 3.7.17.1 is when fuel assemblies are stored in the fuel storage pool and a fuel storage pool verification has not been performed since the last movement of fuel assemblies in the fuel storage pool.
The fuel storage verification is performed after fuel is moved into, out of, or within the spent fuel pool to validate that all fuel assemblies are stored in their proper location. When fuel movement begins SCE is then required to sample boron every seven days in accordance with SR 3.7.17.1 until such time as the fuel storage validation is complete. Once the fuel storage validation is completed showing all fuel is properly stored SR 3.7.17.1 is no longer applicable and the spent fuel pool is sampled in accordance with the requirements of LCS 3.7.116.
The Basis for applicability for the Limiting Condition of Operation (LCO) for TS 3.7.17.1 is that it applies whenever fuel assemblies are stored in the spent fuel pool until a complete spent fuel pool verification has been performed following the last movement of fuel assemblies in the spent fuel pool. This LCO does not apply following the verification since the verification would confirm that there are no misloaded fuel assemblies. With no further fuel assembly movements in progress, there is no potential for a misloaded fuel assembly or a dropped fuel assembly.
Notwithstanding the TS and LCS applicability described above it has been SCE's practice to sample SFP boron concentration weekly. Additionally, SCE intends on deleting LCS 3.7.116 following the approval of the proposed amendment to revise the SFP boron concentration.
1 of 2
Responses to NRC Staff Questions Regarding Proposed Change Notice (PCN) 556 NRC Question 2:
Given the many dilution paths mentioned, describe how the 7 day surveillance interval is adequate to detect slow boron dilution events. In particular, address the case where unborated makeup is provided for a small (1 - 2 gallons per minute) leak that may be overlooked as an unusual condition and processed through radwaste or be otherwise undetected.
SCE Response to Question 2:
SCE plans to provide the answer to this question by the end of December 2006.
This schedule has been discussed with the NRC Project Manager and we understand it is acceptable.
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