ML21165A082
| ML21165A082 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/03/2021 |
| From: | Bates A Southern California Edison Co |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML21165A082 (13) | |
Text
SOUTHERN CALIFORNIA Al Bates Manager EDISON'© Regulatory Affairs An EDISON INTERNATIONAV!l Company 10 CFR 50.59 10 CFR 50.71 10 CFR 72.48 June 3, 2021 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
Subject:
Docket Nos. 50-206, 50-361, 50-362, and 72-41 Facility Change Report, Summary Report of Commitment Changes San Onofre Nuclear Generating Station (SONGS) Units 1, 2, 3, and the Independent Spent Fuel Storage Installation
Dear Sir or Madam:
The attached enclosures contain the Facility Change Report required by 10 CFR 50.59(d)(2) for SONGS Units 1, 2 and 3, and by 10 CFR 72.48( d)(2) for the SONGS ISFSI during the reporting period from April 2, 2019 through April 2, 2021. There was one 10 CFR 50.59 evaluation performed for SONGS Units 1, 2 and 3 during this period which is summarized in Attachment 1.
Brief descriptions of 10 CFR 72.48 evaluations performed for the SONGS ISFSI are included in . Complete change documentation for SONGS evaluations performed in accordance with 10 CFR 50.59 and 10 CFR 72.48 is available onsite. ,
This letter also provides a list of commitments that were determined to be no longer applicable to SONGS following the guidance of Nuclear Energy Institute (NEI) 99-04, "Guidance for Managing NRC Commitment Changes," Revision 0, for the reporting period of April 2, 2019 through April 2, 2021, (Attachment 3). Those commitments that remain applicable to SONGS are provided in Attachment 4.
On August 10, 2020, SONGS implemented License Amendments 237 and 230 to the Units 2 and 3 Technical Specifications (TS) to reflect the permanent removal of spent fuel from the Spent Fuel Pools. These amendments deleted TS 5.4.4 which allowed for changes to the TS Bases to be made without prior NRC approval (Unit 1 TS was previously deleted). For the period prior to the deletion of the SONGS Units 2 and 3 TS, (i.e., April 2, 2019 through August 10, 2020) there were no changes made to the TS Bases. Going forward, the reporting of TS Bases changes will not be part of this report since the SONGS Bases Control Program and associated requirements have been eliminated.
There are no new commitments in this letter or the enclosures.
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Document Control Desk If you have any questions, please contact me at (949) 368-7024.
Sincerely, Attachments:
- 1. SONGS Units 2 and 3 10 CFR 50.59 Evaluation Summary
- 2. SONGS ISFSI 10 CFR 72.48 Evaluation Summaries
- 4. SONGS Units 1, 2, and 3 Commitments Applicable to SONGS cc: S. A. Morris, Regional Administrator, NRC Region IV A. M. Snyder, NRC Project Manager, SONGS Units 1, 2 and 3
ATTACHMENT 1 SONGS UNITS 2 AND 3 10 CRF 50.59 EVALUATION
SUMMARY
FOR THE PERIOD APRIL 2, 2019 TO APRIL 2, 2021
ATTACHMENT 1 - SONGS 10 CFR 50.59 EVALUATION
SUMMARY
Change Number and
Title:
SDS-1-C-PV-1248 Rev.0, Unit 1 RPV Rigging and Handling Evaluation Summary:
The proposed activity evaluated with this change was the removal of the Unit 1 Reactor Pressure Vessel (RPV) package from its onsite storage location at the North Industrial Area (NIA) and the rigging and lifting of the waste package onto a transportation vehicle within the Owner Controlled Area (OCA) for subsequent transport to a waste disposal facility. The postulated scenario that was the subject of the evaluation was a seismic event occurring at the time the RPV was lifted that could have resulted in the RPV package sliding off the climbing jacks or the header beam sliding off its support, causing the load to drop approximately six feet.
Though unlikely, this postulated scenario was evaluated with the respect to the design function of the Unit 1 RPV package to provide shielding against the contained radiation source, the RPV.
Based on the weight, postulated height, and the robustness of the Unit 1 RPV package, it was conservatively projected that the Unit 1 RPV package outer encasement could experience limited damage, but the reactor vessel would remain undamaged. It was concluded that should the outer encasement be breached, the resulting dose to the atmosphere from the exposed metal RPV would be inconsequential relative to the limits of 10 CFR 100. The evaluation of the proposed change was also used to modify statements in the Unit 1 DSAR that referenced the onsite storage location of the vessel.
Attachment 1, Page 1 of 1
ATTACHMENT 2 SONGS ISFSI 10 CRF 72.48 EVALUATION SUMMARIES FOR THE PERIOD APRIL 2, 2019 TO APRIL 2, 2021
ATTACHMENT 2- SONGS 10 CFR 72.48 EVALUTATION SUMMARIES Change Number and
Title:
0718-10512-3, Review of the Analyses Supporting a Cask Tip-over Event Evaluation Summary:
The SONGS Units 2 and 3 UFSAR historically addressed a cask drop in the Fuel Handling Building cask loading pool. With the addition of a single-failure proof crane, the event was better characterized as a tip-over and fall rather than a dropped load. A cask tip-over event was postulated to occur from the upper shelf of the Cask Loading Area (CLA), caused by an earthquake during transition of the cask from the lift yoke extension when the single failure proof cask handling crane was disconnected. Although this practice was discontinued in the fuel transfer campaign, a review of the licensing basis was warranted.
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The postulated tip-over event addressed three specific impacts to the design basis function:
potential dose consequences, impact to the CLA wall, floor and associated liner, and the reaction force loading on the canister. The event and possible impacts were found to be acceptable. NRC Regional Inspectors have reviewed this evaluation and their findings were discussed in Inspection Report 2018-006/2018/002 (ADAMS Accession No. ML19190A217).
Change Number and
Title:
0618-48522-5, Revised Minimum Thread Engagement for Mating Device Bolted Joints Evaluation Summary:
The spent fuel transport device, Hi-TRAC, to mating device flange joint bolting called for a 2.5" thread engagement to provide an adequate stack-up during various design basis events.
However, two of the installed bolt holes were stripped on the mating device when attempts were made to level the HI-TRAC with the mating device attached. This resulted in a reduced thread engagement to 1. 75" for that particular joint. A site-specific analysis was performed to demonstrate that the reduced thread engagement provided an adequate factor of safety for the joint's structural adequacy and capability. The analysis was used to support a "use as is" disposition of the non-conforming condition. This evaluation was a revision to a similar evaluation reported in the previous SONGS Facility Change Report.
Attachment 2, Page 1 of 2
ATTACHMENT 2 - SONGS 10 CFR 72.48 EVALUTATION SUMMARIES Change Number and
Title:
0719-48750 - Compliance with Technical Specifications When Mating Device Installed Evaluation Summary:
Southern California Edison elected to apply Holtec HI-STORM UMAX Certificate of Compliance Technical Specification (TS) 3.1.2 to the multi-purpose canister (MPG) mating device and adapter as a means to ensure an equivalent implementation of the thermal-hydraulic analysis supporting the cooling design function. Doing so required changes to both the UMAX 72.212 report and the relevant site procedures.
Though the TS was intended to apply to a completed spent fuel system canister heat removal system (e.g., when the lid and exhaust vent were installed on the vertically ventilated module),
the content of the TS stated that the provisions of the specification must be satisfied during storage operations (a TS defined term). The TS was recognized to be deficient and changes were with the NRG for review as part of the Amendment 4 request to the TS. Pending approval, it was deemed appropriate to apply the TS to the mating device and adapter configuration. The evaluation reviewed the increased temperature impact imposed by the TS conditions on the configuration and was determined that the process changes could be made without additional NRC notification.
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Attachment 2, Page 2 of 2
ATTACHMENT 3 LIST OF COMMITMENTS NO LONGER APPLICABLE TO SAN ONOFRE NUCLEAR GENERATING STATION AS OF APRIL 2, 2021
ATTACHMENT 3 - LIST OF COMMITMENTS NO LONGER APPLICABLE TO SONGS Commitment Verbatim Commitment to NRC Commitment Source Number 1991-09-001 We are currently completing the procedures to SCE to NRC LTR implement the vendor interface program. These 09/30/1991 procedures will be completed by October 31, 1991.
2004-12-003 SCE is making a regulatory commitment to provide SCE to NRC LTR information to the NRC annually to support the 12/27/2004 apportionment of station dose for SONGS U1, U2
& U3 and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).
2004-12-004 Following approval of this license amendment SCE to NRC LTR request (PCN 555), future revisions to UFSAR 12/27/2004 Chapter 15 design basis accident control room and offsite radiological consequence analyses will be performed using AST methodology.
2007-01-003 SCE will include the SFP external makeup strategy SCE to NRC LTR and SFP external spray strategy in plant 01/10/2007 procedures as described in Tables A.2-1 through A.2-6 of Enclosure 1 rof the source documentl.
2007-01-004 SCE will include the command and control SCE to NRC LTR enhancement strategies in plant procedures as 01/10/2007 described in Table A.3-1 of Enclosure 1 [of the source document].
2007-01-005 SCE will implement the PWR mitigation strategies SCE to NRC LTR in plant procedures as described in Tables A.4-1 01/10/2007 through A.4-7 of Enclosure 1 [of the source document].
2007-01-006 SCE will list the viable site specific reactor/ SCE to NRC LTR containment strategies in appropriate procedures 01/10/2007 that could be used by emergency response organization or plant personnel given in Table A.6-1 of Enclosure 1. Revised commitment: SCE will include viable site specific strategies #33 and #34 for alternate fire water sources given in Table A.2-4 of Enclosure 1 [of the source document] as site-specific SFP mitigation strategies in appropriate plant procedures that could be used by emergency response ornanization or plant personnel.
2007-01-007 SCE will conduct training on the mitigation strategy SCE to NRC LTR procedures/guidelines. Training on the 01/10/2007 procedures will be commensurate with the level of training provided for Severe Accident Management Guidelines (SAMGs).
2007-07-001 SCE will apply a 6.6% reduction to the CECOR SCE to NRC LTR RAI computer code determination of fuel assembly 07/27/2007 burn up for all fuel assemblies prior to determination of the allowable storage location per the proposed TS 4.3.1 and LCS 4.0.100.
Attachment 3, Page 1 of 2
ATTACHMENT 3 - LIST OF COMMITMENTS NO LONGER APPLICABLE TO SONGS Commitment Verbatim Commitment to NRC Commitment Source Number 2013-06-001 Revise procedures to incorporate multi-unit, multi- SCE to NRC LTR source dose assessment by manually summing 6/28/13 the individual dose assessment results for each unit.
2013-06-002 Complete ERO training regarding multi-unit, multi- SCE to NRC LTR source dose assessment by manually summing 6/28/13 the individual dose assessment results for each unit.
2014-01-001 Report on changes to Mitigating Strategies. SCE to NRC LTR Update Commitment Chanqe Report dated 1/2/14. 1/2/14 2014-09-001 Procedures will be revised to ensure that walk- SCE to NRC LTR downs and patrols [of SFP systems] are 9/9/2014 periodically (no less than once a shift) performed.
2015-02-001 SCE will ensure licensee-controlled documents are SCE to NRC LTR in place to require the continuing performance of 2/23/2015 the Hazardous Cargo Traffic Report. The report will include hazardous cargo traffic on Interstate 5 and the adjacent railway line and be submitted to the NRC regional administrator every three years.
flater revised to every five years.]
Attachment 3, Page 2 of 2
ATTACHMENT 4 LIST OF COMMITMENTS APPLICABLE TO SAN ONOFRE NUCLEAR GENERATING STATION AS OF APRIL 2, 2021
ATTACHMENT 4- LIST OF COMMITMENTS APPLICABLE TO SONGS Commitment Status Verbatim Commitment to NRC Commitment Number Source 2010-08-009 Fulfilled Modify the ECP procedure SO123-XXIV- SCE to NRC LTR 10.1, Att. 12), to provide the engineer 8/30/10 responsible for installing the design change with guidance as to when SPI owner must be notified of a field change.
2007-09-001 Fulfilled For all heavy load lifts, ensure NEI 08-05 commitments to safe load paths, load handling procedures, training of crane operators, use of special lifting devices, use of slings, crane design, and inspection, testing, and maintenance of the crane are adequately implemented and reflected in plant procedures.
2006-05-006 Fulfilled Make informal notification as soon as SCE to NRC LTR practicable to appropriate State/Local 8/1/2006 NEI 07-07 officials, with follow-up notification to the NRC, as appropriate, regarding significant onsite leaks/spills into groundwater (see Item 2.1) and onsite or offsite water sample results exceeding the criteria in the REMP (see Item 2.2).
2006-05-005 Fulfilled Submit a 30-day report to the NRC for SCE to NRC LTR any water sample result for onsite 8/1/2006 NEI 07-07 groundwater that is or may be used as a source of drinking water that exceeds the criteria in the licensee's existing REMP for 30-day reporting of offsite water sample results. Copies of 30-day reports for both onsite and offsite water samples will also be provided to the appropriate State agency; 2006-05-004 Fulfilled Document all onsite groundwater sample SCE to NRC LTR results and a description of any 8/1/2006 NEI 07-07 significant onsite leaks/spills into groundwater for each calendar year in the Annual REMP Report, beginning with the report covering the calendar year 2006.
2006-05-003 Fulfilled Put in place a company/site-specific SCE to NRC LTR action plan(s) to help assure timely 8/1/2006 NEI 07-07 detection and effective response to situations involving inadvertent radiological releases in groundwater to prevent migration of licensed radioactive material offsite and quantify impacts on decommissioninQ.
Attachment 4, Page 1 of 2
ATTACHMENT 4- LIST OF COMMITMENTS APPLICABLE TO SONGS 1998-12-001 Fulfilled SCE will decontaminate and dismantle SCE to NRC LTR the facilities and structures that will 12/15/1998 remain to support spent fuel and Greater Than Class C (GTCC) waste storage in the ISFSI after the spent fuel and GTCC wastes are removed from the site.
1997-11-002 Fulfilled Revise its 10 CFR 50.59 program to be SCE to NRC LTR consistent with NEI 96-07, Revision 1. 11/17/1997 These requirements are incorporated in SO123-XV-44 Rev 19. [Revised: 50.59 program is consistent with NEI 96-04, 72.48 program is consistent with NEI 12-04]
1990-03-006 Fulfilled The consolidated NRC open item and SCE to NRC LTR commitment tracking program will be 03/19/1990 implemented by June 1, 1990. Review of NRC commitments and tracking program documentation will' be completed by Auqust 1, 1990.
1990-03-003 Fulfilled SCE will develop a severe weather SCE to NRC LTR response procedure in accordance with 03/12/1990 NUMARC 87-00.
Attachment 4, Page 2 of 2