ML20082K349

Responds to Item H of NRC 941114 RAI on Second 10-yr Interval ISI Program for Songs,Units 2 & 3.Rev 3 of San Onofre Unit 2...ISI Program Second Interval... & Rev 3 of San Onofre Unit 3...ISI Program Second Interval... Encl

ML20082K349
Person / Time
Site:	San Onofre
Issue date:	04/17/1995
From:	Marsh W SOUTHERN CALIFORNIA EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20082K351	List: ML20082K349 ML20082K357 ML20082K363
References
TAC-M88906, NUDOCS 9504190247
Download: ML20082K349 (3)

Text

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Southem Califomia Edison Company T 23 PARKER STREET '..

IRVINE, CALIFORNIA 92718  !'[

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WALTER C. MARSH April 17,1995 m , _ ~e Q

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g U. S. Nuclear Regulatory Commission  %.

Attention: Document Control Desk i Washington, D.C. 20555  ?

Gentlemen: @

Subject:

Docket Nos. 50-361 and 50-362 Second 10-Year Interval Inservice Inspection Program H R

San Onofre Nuclear Generating Station Units 2 and 3 (TAC Nos. M88906 and M88907) y v.

Reference:

1) Letter from Mel B. Fields (NRC) to Mr. Harold B. Ray ,

(Edison) dateu November 14, 1994;

Subject:

Request for Q Additional Information on the Second 10-Year Interval -

Inservice Inspection Program for San Onofre Nuclear l.6 ;. 3 Generating Station, Units 2 and 3 (TAC Nos. M88906 and 9 .

M88907)

2) Letter from Walter C. Marsh (Edison) to the Document Control .[.

Desk (NRC) dated January 13, 1995;

Subject:

Docket Nos. 7 50-361 and 50-362 Second 10-Year Interval Inservice i Inspection Program, San Onofre Nuclear Generating Station Units 2 and 3 (TAC Nos. M88906 and M88907)

This letter provides information for the NRC to complete the review of the  ; c.

Second 10-year In3ervice Inspection (ISI) Interval Program for San Onofre Units 2 and 3. In reference 1, the NRC requested additional information (*

llMed as items A through H. Southern California' Edison (Edison) responded to :1; NRC Items A through G in reference 2; this letter responds to NRC Item H, which is the following: .y 4.n H. Paragraph 2.1.10 of the program states that relief requests from the 7:'

first and second intervals have been incorporated into the plan as .

substitute examinations, tests, or repairs. The proposed method lacks i:

sufficient information to evaluate the acceptability of alternatives. 2.0 Examples of insufficient information include: Alternate Examination W 2.9.2, which does not contain a basis for the alternative examination, .fs and Substitute Examination 3.2.2.1, which does not include the percent .F coverage attainable for the examination. Where Code requirements are A#

not being met, the licensee shall submit requests for relief for staff review pursuant to 10 CFR 50.55a(g)(5). Relief granted for the first 6 10-year in+erval cannot be assumed for the second 10-year interval. :4 Please provide the necessary requests for relief for all areas where the 1 Code requirements will not be met far the second 10-year interval. For E use as a suggested guide when preparing requests for relief, attached is ('

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l 950419054 ^955437 PDR

[I O ADDCK 05000361 1  ?

PDR i

r f [2-5 Document Control Desk -

Appendix A, " Inservice Inspection: Guidance for Preparing Requests for Relief from Certain Code Requirements Pursuant to 10 CFR 50.55a(g)(5)".

Response

In response to the two items identified where additional information is needed to evaluate the acceptability of alternatives, the following clarifications are proviced:

1) Section 2.9, Alternative Examinations, is revised to describe how Alternate examination methods, as allowed by ASME Code Section IWA-2240, will be implemented at San Onofre. The specific items that were originally in section 2.9 have been removed because, with the exception of item 2.9.3, they were already allowed by NRC approved Code Cases and discussed in other sections of the report.

Item 2.9.3 has been revised and is now included as a Substitute Examination in Section 3.3.5.

2) In Section 3.2.2.1, Successive Examinations, Categories C-F-1 and C-F-2, the percent coverage attainable for the inspection is provided on page 3 of Appendix 8.0 of the program. This is not a request for relief, it is a description of how we are complying with the requirements of ASME Code Sections IWC-2500-1 and IWC-1220.

The San Onofre Units 2 and 3 ISI programs describe how Edison implements the requirements of the 1989 Edition of the ASME Code. Sections 3.3 and 3.4 of the programs describe substitute examinations and repairs. Because these '

examinations and repairs deviate from what the ASME Code allows, NRC approval is required. Sections 3.3, 3.4, and 3.5 were called out and the need for NRC approval was identified in the October 4,1993, cover letter which transmitted the San Onofre Units 2 and 3 ISI Programs. Section 2.1.10, of the programs, also identify that relief requests from the first ten-year interval are incorporated into Sections 3.3, 3.4, and 3.5. Section 3.5 is deleted by Revision 3 to the programs because we meet the 1989 Code requirements.

Therefore, substitute tests are not needed.

In reading 10 CFR 50.55a and ASME Code Sections IWA-2240(5) and Appendix F, Article F-3000, Edison interprets that the Program document for an interval should identify any deviations from the Code to the NRC and NRC approval of the deviations is needed. Edison concludes the appropriate classifications should be as Substitute Examinations, Substitute Repairs, and Substitute Tests for the deviations identified in the Program document in accordance with 10 CFR 50.55a(g)(5)(iii). Edison believes that a Relief Request should be used when, during an interval, it becomes apparent that the Code can not be met, and relief is required in accordance with 10 CFR 50.55a(g)(5)(iv). Edison came to this conclusion because this is an original submittal of the Program document, and not a mid-interval request for relief. Therefore, the substitute examinations, repairs, and tests are not labeled with a relief request designator.

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Document Control Desk f [3-5 However, every examination, repair, or test, (that has been identified in the )

preparation of the program) where NRC approval is required to deviate from the <

Code is identified in Sections 3.3 and 3.4. These sections have been {

rewritten to ensure all of the information required by Appendix F of thin ASME Code to support NRC review and approval of the substitute examination, repair, or test is included in these sections.

Revision 3 to the Inservice Inspection Programs at San Onofre '. hits 2 and 3 addresses the issues raised by the NRC in Item H. Change bars identify the paragraphs changed by revision 3. By enclosure, we are resub:nitting the ISI Program documents for Units 2 and 3, except for copies of the drawings.

Please let me know if you have any additional questions.

I Sincerely,

'f50. W i t

Enclosures l cc: L. J. Callan, Regional Administrator, NRC Region IV  !

A. B. Beach, Director, Division of Reactor Projects, Region IV  !

K. E. Perkins, Jr., Director, Walnut Creek Field Office, NRC Region IV J. A. Sloan, NRC Senior Resident Inspector, San Onofre Units 2 & 3 l M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3 )

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