ML080080056

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Request to Be Considered a PWR Improved Technical Specification Pilot Plant for Risk Informed Initiative 4b, Flexible Allowed Outage Times
ML080080056
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 01/04/2008
From: Ridenoure R
Southern California Edison Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NUREG-1432
Download: ML080080056 (2)


Text

F~~ISOUTHERN CALIFORNIA Ross T. Ridenoure IflIC&NiVP and Site Manager ED.LLISON"'

San Onofre Nuclear Generating Station An EDISON INTERNATIONALw Company January 4, 2008 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Docket Numbers 50-361 and 50-362 Request to be Considered a PWR Improved Technical Specification Pilot Plant for Risk Informed Initiative 4b, Flexible Allowed Outage times San Onofre Nuclear Generating Station, Units 2 and 3

Dear Sir or Madam:

By letter dated July 13, 2007, the NRC issued license amendments for South Texas Project (STP) Units 1 and 2, approving risk based extensions to selected technical specifications. The approval revised limiting conditions for operation to permit extending the completion times of action requirements subject to the requirement that the risk is assessed and managed. A new Configuration Risk Management Program was added to the STP technical specifications under Administrative Controls.

Southern California Edison (SCE) intends to submit a similar risk-informed license amendment request as a pilot plant for the Pressurized Water Reactors Owners' Group (PWROG) Improved Technical Specifications (ITS). SCE will work with the PWROG and the Nuclear Energy Institute (N El) in developing the license amendment request in parallel with a corresponding Technical Specification Task Force (TSTF) Traveler. The SONGS submittal will follow NEI 06-09, "Risk-informed Technical Specifications Initiative 4b Risk-Managed Technical Specifications (RMTS) Guidelines." The SONGS Technical Specifications are based on NUREG-1432, "Standard Technical Specifications Combustion Engineering Plants.

This pilot submittal will assist the staff in identifying enhancements to the NRC's generic regulatory program by identifying process improvements for review of a license amendment request for a Pressurized Water Reactor plant with ITS.

Additionally, lessons learned will be identified for incorporation into future updates of NEI 06-09 Guidelines, Regulatory Guide 1.200, "An Approach for Determining the Technical Adequacy of PRA Results for Risk-Informed Activities," and the forthcoming TSTF traveler for Initiative 4b submittals.

Mail Drop D45 P.O. Box 128 San Clemente, CA 92672 949-368-6255 PAX 86255 Fax: 949-368-6183 Ross. Ridenoure@sce.com K

Document Control Desk-2Jaur4,08 January 4, 2008 The SONGS, Units 2 and 3 proposed application will apply the SONGS, Units 2 and 3 Probabilistic Risk Analysis to calculate the changes in risk (i.e.,

instantaneous core damage frequency, instantaneous large early release frequency) based on the actual plant configuration. By comparing the calculated risk to pre-determined risk thresholds, the SONGS configuration risk management program (CRMP) will be capable of providing both a technical basis and robust calculation of an acceptable configuration-specific, risk-informed completion time (RICT). The CRMP will be an extension of the program that is currently used to perform the assessment of plant risk required by 10 CFR 50.65(a) (4).

As allowed by 10 CFR Part 170.11 (a)(1 )(iii) as a means of exchanging information between industry organizations and the NRC for the specific purpose of supporting the NRC's generic regulatory improvements or efforts, SCE requests that the review fees be waived for this application in accordance with 10 CFR Part 170.11 (b)(11).

SCE plans to submit the proposed license amendment by September 30, 2008 and will request NRC approval by September 30, 2009.

If you have any questions or require additional information, please contact me.

Sincerely, cc,.

E. E. Collins, Regional Administrator, NRC Region IV N. Kalyanam, NRC Project Manager, San Onofre Units 2 and 3 C. C. Osterholtz, NRC Senior Resident Inspector, San Onofre Units 2 and 3 W. M. McCabe, NRC Chief Financial Officer S. Y. Hsu, California Department of Public Health, Radiologic Health Branch