ML19158A092
| ML19158A092 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 06/04/2019 |
| 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: ML19158A092 (69) | |
Text
SOUTHERN CALIFORNIA EDISON~
An EDISON INTERNATIONAM' Company U. S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, D.C. 20555-0001 June 4, 2019
Subject:
Docket Nos. 50-206, 50-361, 50-362, and 72-41 Al Bates Manager Regulatory Affairs &
Nuclear Oversight 10 CFR 50.59 10 CFR 50.71 10 CFR 72.48 Facility Change Report, Summary Report of Commitment Changes, and Cycle Specific Technical Specification Bases Page Updates 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 San Onofre Nuclear Generating Station (SONGS) Units 1, 2 and 3, and by 1 O CFR 72.48( d)(2) for the SONGS ISFSI during the reporting period from April 1, 2017 through April 1, 2019. The enclosed reports provide a brief description and summary of any 1 O CFR 72.48 evaluations performed for the SONGS ISFSI (Enclosure 1 ). There were no 1 O CFR 50.59 evaluations performed for SONGS Units 1, 2 or 3 during this time period. Complete change documentation for the SONGS 10 CFR 72.48 evaluations performed for the SONGS ISFSI is available onsite.
The letter also provides the report of the commitment changes following the guidance of Nuclear Energy Institute (NEI) 99-04, "Guidance for Managing NRC Commitment Changes"' Revision 0, for the reporting period of April 1, 2017 through April 1, 2019. Enclosure 2 provides a list of the commitments that were changed and identified using the NEI 99-04 process as commitment changes that should be included in the NRC summary report. The 334 commitments identified in Enclosure 2 are no longer applicable due to the plants being in a shutdown condition. Enclosure 3 provides a list of the.26 commitments that are still applicable to SONGS as of April 1, 2019. SONGS continues to comply with these commitments As required under SONGS Units 2 and 3 Technical Specification (TS) 5.4.4, changes to the SONGS Units 2 and 3 TS Bases made without prior Nuclear Regulatory Commission (NRC) approval are to be provided to the NRC on a frequency consistent with 10 CFR 50.71(e). The reporting period for the changes to the SONGS Units 2 and 3 TS Bases is from April 1, 2017 through April 1, 2019. Only one TS Bases change package was processed during this time frame. The affected TS Bases pages are provided in Enclosure 4 of this letter.
Document Control Desk This letter or the attached enclosures do not contain any new commitments.
Should you have any questions or require additional information, please contact me at (949) 368-6945.
Enclosures:
- 1. SONGS ISFSI 10 CFR 72.48 Evaluations Summaries For The Period From April 1, 2017 Through April 1, 2019
- 2. List of Commitments No Longer Applicable to SONGS as of April 1, 2019
- 3. List of Commitments Applicable to SONGS as of April 1, 2019
- 4. SONGS Units 2 and 3 Revised Technical Specification Bases Changes for the Period from April 1, 2017 Through April 1, 2019 cc: S. Morris, Regional Administrator, NRC Region IV M. G. Vaaler, NRC Project Manager, San Onofre Units 1, 2 and 3
ENCLOSURE 1 SAN ONOFRE NUCLEAR GENERATION STATION ISFSI FACILITY CHANGE REPQRT (FCR) 10 CRF 72.48 EVALUATION SUMMARIES FOR THE PERIOD FROM APRIL 1, 2017 THROUGH APRIL 1, 2019
- 1. Change Number and
Title:
1117-45514-2, SONGS HI-STORM UMAX Version MSE System ISFSI 10 CFR 72.212 Report
==
Description:==
SONGS is utilizing the Holtec International (Holtec) Underground Maximum (UMAX) Storage System for the storage of the remaining SONGS Units 2 and 3 spent fuel at the expanded onsite Independent Spent Fuel Storage Installation (ISFSI). In a limited number of cases, the inputs to the generic analyses used to support the UMAX licensing bases (Certificate of Compliance and Final Safety Analysis Reports) did not fully bound or were inconsistent with SONGS site-specific conditions. In those cases, Regulatory Issue Summary 12-05 requires a review under 1 O CFR 72.48 to be performed by the general licensee (SCE/SONGS). The following three issues were addressed in the evaluation.
The site-specific fire analysis increases the multi-purpose canister (MPC) temperature and pressure to values slightly higher than previously analyzed within the HI-TRAC in the HI-STORM FW FSAR. This increase was due to the consideration of additional combustibles potentially present. The generic analysis relies solely on 50 gallons of fuel.
At SONGS it is necessary to swap yokes while the HI-TRAC is placed on a shelf in the cask handling pool. During that swap, the HI-TRAC is unrestrained and could fall from the shelf into the cask handling pool during a seismic event. The lateral loading impact on the MPC within the overpack was not addressed in the UMAX licensing bases, (though was found to be acceptable using analyses developed and reviewed by the NRC in support of the licensing of the HI-STAR-190 transportation package). The lateral loading is addressed under 72.48 since the focus is the design functions of the MPC; not Part 50 Structures, Systems, and Components. The potential dose impacts were previously added to the SONGS UFSAR (authorized under 1 O CFR 50.59). The potential impact on the cask handling pool floor was bounded by existing SONGS analysis performed for the drop of equivalent equipment during the previous TransNuclear loading campaigns. Note that while evaluation of this issue was included in the original 1 O CFR 72.48 evaluation (1117-45514-2), that portion of the evaluation was later superseded by a 10 CFR 72.48 screen. Therefore, a summary of the 72.48 evaluation of this issue is not provided below.
The SONGS design and licensing basis postulated tornado borne missiles differ from those addressed in the HI-STORM FW FSAR. The SONGS missiles impart slightly higher kinetic energy to the various targets for moderate and small missile scope.
Evaluation Summary:
The Fire Hazards analyses summarized in the 72.212 Report addresses both transfer (pool to pad) and down-loading conditions. The equipment used to support those operations (Vertical Cask Transporter and HI-PORT) are the major sources of combustibles during transfer and on the pad. Site hazards during transfer were evaluated and appropriate administrative controls (limitations on content volumes and stand-off distance) are well-established and controlled throughout transfer operations. Once placed in the Vertical Ventilated Module (WM) and the lids are in-place, there is minimal potential for impact on the MPC contained therein.
Nevertheless, transient combustibles are generally prohibited and require explicit authorization if present. The results of the site-specific analysis conclude that the fire impact on the MPC's is bounded by other generic, NRC approved, condition evaluations., Page 1
The SONGS licensing basis tornado missile hazards required by the Units 2 and 3 UFSAR/Defueled Safety Analysis Report (DSAR) are generally bounded by the generic HOL TEC analysis in the associated storage system FSARs. Wind speed and pressure drop have considerable margin over the SONGS licensing basis. However, the spectrum of missiles postulated in the SONGS licensing basis is somewhat different. HOL TEC has previously evaluated a wider range of missiles as part of the implementation of their systems at other sites using the HI-STORM 100 and FW systems, as well as the HI-STORM UMAX system. The SONGS missile spectrum was bounded by this generic analysis. Further, the concrete monolith surrounding the WM at SONGS limits the potential targets during storage and to the lids which are themselves quite robust structurally. Tornado missile impacts are not a significant threat to the integrity of the WM. During transfer operations, the HI-TRAC on the HI-PORT is evaluated for both penetrations and tip-over. These evaluations demonstrate the capacity of the HI-TRAC to remain on the HI-PORT and withstand such missile impacts.
Therefore, the proposed activities may be implemented without obtaining an amendment to the license or Coe.
- 2. Change Number and
Title:
0618-48522-5, Revised Minimum Thread Engagement for Mating Device Bolted Joints
==
Description:==
Bolted joints connect the HI-TRAC to the Mating Device, the Mating Device to the Adapter and the Adapter to the Cavity Enclosure Container. This stack-up supports the HI-TRAC and must be capable of withstanding a full range of design loading conditions. The engagement of the bolts at each joint are integral to the strength of the joint and affects the safety factor of the bolt under design loading conditions. This change adopts reduced thread engagement for the HI-TRAC to Mating Device joint from 2.5" to 1.625" based on a site-specific analysis to support a "use-as-is disposition" of a non-conforming condition.
Evaluation Summary:
The design function is to provide structurally adequate/capable joints to sustain the stack-up during various design basis events. Analysis demonstrates that the reduced thread engagement provides an adequate factor of safety in support of this function. Therefore, the change has no substantive adverse impacts to design functions, and does not require a license amendment under 72.48(c)(i-viii).
- 3. Change Number and
Title:
0119-53878-5, Load Monitoring System (LMS)
Unavailability
==
Description:==
Via a separate activity, SCE has installed an LMS on the Vertical Cask Transporter used to support canister transport and down-loading on the SONGS Independent Spent Fuel Storage, Page 2
Installation. The installation of the LMS was authorized using a 72.48 screen. Following installation of the LMS, a separate activity was proposed to provide administrative controls (procedural steps) outlining appropriate actions to take should the LMS fail during down-loading operations. These administrative controls were then described in the 72.212 Report. The proposed activity summarized below includes changes to the 72.212 Report and associated administrative controls outlining appropriate actions to take should the LMS fail during down-loading operations.
Evaluation Summary:
The procedure change was implemented to provide actions to take should the LMS fail during downloading operations. There is not a more than minimal increase in the consequences of this malfunction of equipment important to safety, nor is there a malfunction with a different result due to these pre-planned actions., Page 3
ENCLOSURE 2 LIST OF COMMITMENTS NO LONGER APPLICABLE TO SAN ONOFRE NUCLEAR GENERATING STATION AS OF APRIL 1, 2019
Commitment Number Verbatim Commitment to NRC Commit Source 2014-10-002 SCE will implement a routine activity to periodily operate the spent fuel SCE to NRC L TR purification pumps. Initial operation will be performed prior to end of year.
10/27/2014 2010-09-007 By December 31, 2012, Condition Assessment Plan(s) Develop or identify existing SCE to NEI LTR condition assessment plans that will provide reasonable assurance of integrity of 06/28/2010 components within the additional scope of the Underground Piping and Tanks Integrity Initiative. These plans shall include the following key attributes:
Identification of underground piping and tanks to be assessed Potential assessment techniques. Assessment schedules that take into account the relative priority of components. This schedule should be coordinated with the schedule developed for the original Buried Piping Integrity Initiative to ensure that the components with the highest overall priority are addressed first. Assessment of cathodic protection, if applicable 2010-08-029 The following compensatory measures apply to the Unit 3 Cycle 16 refueling only SCE to NRC LTR since Unit 3 steam generator replacement is planned for this outage: There are to 08/16/2010 be no load movements by the service crane over the switchyard.
2010-08-028 The following compensatory measures apply to the Unit 3 Cycle 16 refueling only SCE to NRC LTR since Unit 3 steam generator replacement is pianned for this outage: Work 08/16/2010 controls to be in place to lay the service crane boom down prior to severe weather.
2010-08-027 The following compensatory measures apply to the Unit 3 Cycle 16 refueling only SCE to NRC LTR since Unit 3 steam generator replacement is planned for this outage: A Unit 3 08/16/2010 Cycle 16 shutdown qualitative risk assessment to be performed to provide qualitative risk management actions to demonstrate acceptable outage risk during construction, use, and deconstruction or the OLS., Page 1 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 2010-08-026 The following compensatory measures apply to the Unit 3 Cycle 16 refueling only SCE to NRC LTR since Unit 3 steam generator replacement is planned for this outage: SONGS 08/16/2010 NU REG 0612 heavy loads procedural requirements are to be implemented for both the OLS and the service crane to ensure safe load paths are followed, or safe shutdown equipment is taken out of service, during the rigging activity.
2010-08-025 The following compensatory *measures apply to the Unit 3 Cycle 16 refueling only SCE to NRC L TR since Unit 3 steam generator replacement is planned for this outage: OLS 08/16/2010 construction, use, and removal to be limited to specific outage windows to reduce risk to the Unit 3 Tn A diesel generator cables.
2010-08-024 The following compensatory measures apply to the Unit 3 Cycle 16 refueling only SCE to NRC LTR since Unit 3 steam generator replacement is planned for this outage: Rigging 08/16/2010 activities to be limited to one end of the steam generator replacement outside lift system (OLS) to limit potential impact to Unit 3 Tn A diesel generator cables located underground near the containment equipment hatch.
2010-08-023 Bus outages are to be performed during the core offload window, when all fuel is SCE to NRC LTR removed from the reactor vessel.
08/16/2010 2010-08-022 Outage Unit Compensatory Measures Develop a plan to effect an emergency SCE to NRC LTR return to service, if required to support the operating unit.
08/16/2010 2010-08-021 Outage Unit Compensatory Measures Scheduling: Work the supply cubicles and SCE to NRC LTR cross-tie cubicle bottle replacements first, allowing for a quicker emergency 08/16/2010 return to service.
2010-08-020 Outage Unit Compensatory Measures: Establish Switchyard Restricted Access, SCE to NRC LTR during the once-per-tn 10-day Completion Time for one offsite power source 08/16/2010 inoperable.
2010-08-019 Outage Unit Compensatory Measures Protect all available tn safety function SCE to NRC LTR equipment CCW (component cooling water), SWC (saltwater cooling), SOC 08/16/2010 (shutdown cooling), and SFP (Spent Fuel Pool) cooling., Page 2 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 2010-08-018 Outage Unit Compensatory Measures Protect the available tn onsite source, EDG SCE to NRC L TR and 4.16 kV bus.
08/16/2010 2010-08-017 Outage Unit Compensatory Measures Protect the available tn offsite source: via SCE to NRC LTR switchyard barriers and 4.16 kV cross-tie breaker barriers.
08/16/2010 2010-08-016 Online Unit Compensatory Measures - On-Line Unit (MODES 1 to 4) Do not allow SCE to NRC LTR any switchyard work, or tn work on the protected tn.
08/16/2010 2010-08-015 Online Unit Compensatory Measures - On-Line Unit (MODES 1 to 4) Protect SCE to NRC LTR switchgear room normal HVAC cooling unit and exhaust fan.
08/16/2010 2010-08-014 Online Unit Compensatory Measures - On-Line Unit (MODES 1 to 4) Protect all 3 SCE to NRC L TR AFW pumps 08/16/2010 2010-08-013 Online Unit Compensatory Measures - On-Line Unit (MODES 1 to 4) Ensure SCE to NRC LTR common equipment (lE 480 VAC buses, emergency chillers, control room 08/16/2010 emergency cooling units) are aligned to the on-line unit.
2010-08-012 Online Unit Compensatory Measures - On-Line Unit {MODES 1 to 4) Ensure the SCE to NRC LTR protected tn is the tn with the Operable 4.16 kV cross-tie.
08/16/2010 2010-08-011 Online Unit Compensatory Measures - On-Line Unit {MODES 1 to 4) Protect both SCE to NRC LTR onsite sources-Perform Surveillances on the operating unit EDGs prior to entering 08/16/2010 Action Statement, and protect the available switchgear room.
2010-08-010 Online Unit Compensatory Measures - On-Line Unit (MODES 1 to 4) Protect the SCE to NRC LTR available offsite source: via switchyard barriers and 4.16 kV cross-tie breaker 08/16/2010 breaker barriers.
2010-01-001 SONGS will continue to implement revised applicability of Technical SCE to NRC LTR Specifications that are pertinent to the movement of fuel assemblies using 01/14/2010 administrative controls in accordance with NRC Administrative Letter 98-10. Due:
Until NRC completes its review and issues revised technical specification pages., Page 3 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 2009-i2-006 SCE will continue to participate in the developement of guidence relative to the SCE to NRC LTR transport of gas voids in suction piping to the ECCS pumps and will re-perform 12/22/2009 the analysis, once the guidence is finalized. SCE will provide a supplemental response with the results of the re-analysis.
2009-11-002 Reference 3 and this supplemental response credit the replacement of Units 2 SCE to NRC LTR and 3 steam generators. The Unit 2 replacement steam generators are being 11/12/2009 installed during the ongoing cycle 16 refueling outage 2009-06-001 Removal of the plant-specific Technical Specification requirements will be SCE to NRC LTR performed concurrently or subsequent to implementation of 10 CFR Part 26, 06/10/2009 Subpart I requirements. This commitment will be completed no later than October 1, 2009 or within 60 days Techni Specification approval, whichever is later.
2009-02-001 The replacement steam generators are to be installed during the U2 Fuel Cycle 16 SCE to NRC LTR refueling outage, currently scheduled to begin in September 2009 and the U3 02/23/2009 Fuel Cycle 16 refueling outage, currently scheduled to begin in October 2010.
2008-10-009 SCE is committing in this submittal to completing a chemical effects retest SCE to NRC LTR program, and identifying any additional required plant modifications, by 10/30/2008 November 20, 2009.
2008-10-008 SCE will conduct confirmatory walkdowns as identified in Item 6 of the Design SCE to NRC LTR Evaluation for Unit 3 accessible and inaccessible piping and submit a Nine-Month 10/14/2008 supplemental response with the results of these walkdowns and any resulting corrective actions.
2008-10-007 SCE will conduct confirmatory walkdowns as identified in Item 6 of the Design SCE to NRC LTR Evaluation for Unit2 accessible and inaccessible piping and submit a Nine-Month 10/14/2008 supplemental response with the results of these walkdowns and any resulting corrective actions., Page 4 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 2008-10-006 SCE is continuing to support the industry and NEI Gas Accumulation Management SCE to NRC LTR Team activities regarding the resolution of generic TS changes via the TSTF 10/14/2008 traveler process. Following NRC approval of this TSTF, SCE will evaluate adopting the TSTF to either supplement or replace current TS and LCS requirements.
2008-10-004 A vent valve will be added to the Tn "A" discharge piping of the high pressure SCE to NRC LTR safety injection pumps in each unit. Due: U2C16 and U3C16 outages scheduled 10/14/2008 for the fall of 2009 and 2010, respectively.
2008-10-001 Tech Spec Bases for SR 3.5.2.4 will be revised to read "Maintaining the piping SCE to NRC LTR from the RWST to the RCS full of water" 90 days after completion of the Unit 3 10/14/2008 Cycle 15 Refueling outage (scheduled for October 2008}
2008-09-006 Prior to implementation of SONGS' proposed Emergency Plan Change, SCE will: 5} SCE to NRC LTR Change the facility activation requirements for the Operations Support Center to 09/24/2008 include the additional 90 minute responders described in the above items 1, 2 and 3.
2008-09-005 Prior to implementation of SONGS' proposed Emergency Plan Change, SCE SCE to NRC LTR will:Ensure that either an l&C Technician or a Shift Rotating General Foreman 09/24/2008 (SRGF} is on-shift at all times 2008-09-004 Prior to implementation of SONGS' proposed Emergency Plan Change, SCE will SCE to NRC LTR Add one (1) Instrument and Control Technician to the automatic recall system.
- 09/24/2008 2008-09-003 Prior to implementation of SONGS' proposed Emergency Plan Change, SCE will SCE to NRC LTR Add one (1) Electrical Maintenance Technician, to the automatic recall system.
09/24/2008 2008-09-002 Prior to implementation of SONGS' proposed Emergency Plan Change, SCE will SCE to NRC LTR Add nine (9) qualified Health Physics (HP} Technicians, to the automatic recall 09/24/2008 system.
2008-06-001 The proposed steam generator plugging criterion is a preliminary value and SCE SCE to NRC LTR will provide a confirmation or a corrected value when the calculation is approved. 06/27/2008, Page 5 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 2008-05-003 SCE will submit a response within nine months of the date of the Generic Letter SCE to NRC L TR providing the results of the evaluation, identifying required confirmatory 05/15/2008 walkdowns that have not been completed, and providing the schedule for their completion.
2008-05-002 Where additional vent valves are deemed to be required, confirmatory SCE to NRC LTR walkdowns will be conducted to verify the need for additional vents.
05/15/2008 2008-05-001 An assessment of the system piping to confirm adequate vent capability will be SCE to NRC LTR performed in order to assure successful management of gas accumulation 05/15/2008 volumes. Potential gas accumulation volumes will be determined by conservatively applying construction tolerances to the plant isometric drawings.
2007-11-011 Equipment that will be used to monitor float current will have the necessary SCE to NRC LTR accuracy and capability to monitor electrical current in the expected range.
11/30/2007 2007-08-002 SCE will relocate specific gravity monitoring to the proposed Battery Monitoring SCE to NRC LTR and Maintenance Program. The specific gravity monitoring will be performed 08/10/2007 prior to each battery discharge test.
2007-08-001 SCE is making a regulatory commitment to maintain a capacity margin (presently SCE to NRC LTR 2%) to account for the uncertainty in the battery capacity assigned by the 08/10/2007 manufacturer associated with the allowed float current limit (presently 1.5 amps) for 1800 amp-hour (AH) batteries. This new commitment will be added to the list of regulatory commitments in the revised submittal. The Licensee Controlled Specification (LCS) will require 0.75 amps or less charging current for the 1260 AH batteries until they are upgraded to 1800 AH batteries.
2007-03-007 Notify me [Jim Dyer, NRC] in writing when you have completed the actions and SCE to NRC LTR commitments addressed in this Confirmatory Action letter.
03/22/2007 2007-03-003 The NRC will be informed if SCE revises the commitment to the enhanced leakage SCE to NRC LTR monitoring program described herein or the commitment to have all pressurizer 03/07/2007 DMWs compliant with MRP-139, prior to operation after 12/31/2007., Page 6 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 2007-03-002 SCE is committing for SONGS U2 and U3 to implement an interim enhanced SCE to NRC L TR leakage monitoring program not later than 3/2/2007, that will remain in effect 03/07/2007 until the unti meets the MRP-139 requirements for pressurizer DMWs.
2006-10-004 A report that summarizes the results of the examinations will be submitted to the SCE to NRC L TR NRC within fourteen days of completion of the final UT examination. The report 10/23/2006 will include the following details as applicable, a listing of indications detected
- the disposition of all indications using the standards of ASME Section XI, IWB-3514-2 and/or IWB-3514-3 criteria the type and nature of the indications, 2 and a discussion of any repairs to the overlay material and/or base metal and the reason for the repair.
2006-10-003 SCE will coordinate with the EPRI NDE Center in developing techniques and a SCE to NRC LTR qualification process to address this examination.
10/23/2006 2006-05-002 INSPECTION RESULTS WILL BE INCLUDED IN THE 60-DAY POST REFUELING SCE to NRC LTR OUTAGE INSPECTION REPORT REQUIRED BY NRC ORDER EA-03-009.
05/11/2006 2006-05-001 IF THE ESTABLISHED INSPECTION CRITERION IS EXCEEDED, SCE WILL PERFORM SCE to NRC LTR ADDITIONAL REPAIRS ON CEDM # 56.
05/11/2006 2006-02-004 Promulgate LCS for upgrade of the battery maintenance practices to conform to SCE to NRC LTR industry standard IEEE 450-2002.
03/30/2007 2006-02-003 Appropriate design features will be added to measure float charging current SCE to NRC LTR when a swing battery charger is aligned to a Class lE subsystem battery.
03/30/2007 2006-02-002 Relocate the requirements of existing SRs 3.8.4.2, 3, 4, 5 from TS to the LCS.
SCE to NRC LTR 03/30/2007 2005-12-001 SCE is committing to follow the NRC's condition of approval of ASME Code Case N SCE to NRC L TR 638-1 as described in the Regulatory Guide 1.147. "UT examinations shall be 12/23/2005 demonstrated for the repaired volume using representative samples which contain construction type flaws. The acceptance criteria of NB -5330 of Section 111 edition and addenda approved in 10 CFR 50.55a apply to all flaws identified within the repaired volume.", Page 7 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 2005-07-005 The maximum rod average burn up is limited to 60 GWD/MTU for ZIRLO clad fuel SCE to NRC LTR 553 assemblies.
-7/18/2005 2005-07-004 The corrosion limit as predicted by the best-estimate model is limited to below SCE to NRC LTR 553 100 microns for all location of the fuel for ZIRLO clad fuel assemblies.
-7/18/2005 2005-07-003 Revise the San Onofre Units 2 and 3 Updated Final Safety Analysis Report as SCE to NRC LTR 553 needed to reflect the changes contained with the Technical Specification changes -7/18/2005 in PCN-553 to allow the use of ZIRLOTM fuel cladding material. The changes shall include, but are not limited to, the following: A. The corrosion limit as predicted by the best-estimate model is limited to below 100 microns for all locations of the fuel for ZIRLOTM clad fuel assemblies. B. The maximum rod average burn up is limited to 60 GWD/MTU for ZIRLOTM clad fuel assemblies. C. Chapter 1 and Chapter 4 will be revised as necessary to reflect the manufacturing and implementation of ZIRLOTM clad fuel rods. D. The applicable sections of Chapter 6 and Chapter 15 will be revised to reflect the re-analysis performed for the ZIRLOTM cladding material.
)
2005-07-002 The baseline FD Im for SONGS will remain unchanged during the process of SCE to NRC L TR 553 collecting additional data to support increasing the FDlm. The restriction on the
-7/18/2005 FD1m for SONGS will be lifted only after consultation with the NRC. CE 16x16 ZIRLOS oxide measurement data used to compare with the expected behaivor will be shared with the NRC. The 100 micron oxide limit will be met regardless of the limit imposed on FDlm.
2005-07-001
- 1) SCE will restrict the modified Fuel Duty Index of each ZIRLO clad fuel pin to SCE to NRC LTR 553 110% of the established SONGS specific FD1m limit of 586 except under the
-7/18/2005 following condition: proceeding 110% limit may be exceeded for a fraction of the fuel pins in up to eight (8) fuel assemblies. For these eight fuel assemblies, SCE will restrict the fuel duty of ZIRLO clad fuel pins to 120% of the SONGS plant specific FDlm limit., Page 8 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 2005-05-005 SCE will use our self-assessment program to document and evaluate any SCE to NRC LTR unexpected problems with the Delta Suit and report any suit defects in a timely 05/11/2005 manner to the United States nuclear industry through our Operating Experience process and to the manufacturer.
2005-05-004 Air hoses of any length can be used, but air shall be supplied to the Delta Suit at SCE to NRC L TR 87 psig +/- 10% in accordance with the manufacturer's "MTH2, Instructions for 05/11/2005 Use,: dated 12/00. The Delta Suit can be fitted with CEJN fittings used at SONGS.
2004-12-002 SCE is making a regulatory commitment to provide to the NRC using an industry SCE to NRC LTR database the operating data (for each endar month) that is described in Generic 12/27/2004 Letter 97-02 Revised Contents of the Monthly Operating Report,by the last day of the month following the end of each endar quarter. The regulatory commitment will be based on use of an industry database (e.g., the industry Consolidated Data Entry (CDE) program, currently being developed and maintained by the Institute of Nuclear Power Operations). This regulatory commitment will be implemented to prevent any gaps in the monthly operating statistics and shutdown experience provided to the NRC (i.e., data for all months will be provided using one or both systems (monthly operating reports and CDE)).
2004-12-001 SCE has verified that a hydrogen monitoring system capable of diagnosing SCE to NRC LTR beyond design-basis accidents is installed at SONGS 2 & 3 and is making a 12/10/2004 regulatory commitment to maintain that capability. The hydrogen monitors will be included in the Licensee Controlled Specifications. This regulatory commitment will be implemented within 60 days of approval ofthis amendment request.
2004-08-005 The applicable sections of Chapter 6 and Chapter 15 will be revised to reflect the SCE to NRC LTR re-analysis performed for the ZIRLO cladding material.
08/26/2004 2004-08-004 Chapter 1 and Chapter 4 will be revised as necessary to reflect the manufacturing SCE to NRC LTR and implementation of ZIRLO clad fuel rods.
08/26/2004, Page 9 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 2004-08-003 The maximum rod average burnup is 60 GWD/MTU for ZIRLO clad fuel SCE to NRC LTR assemblies.
08/26/2004 2004-08-002 Corrosion limit as predicted by the best-estimate model is limited to below 100 SCE to NRC LTR microns for all locations of the fuel for ZIRLO clad fuels assemblies.
08/26/2004 2004-08-001 Revise the U2 & U3 UFSAR as needed to reflect the changes contained with the SCE to NRC LTR TS changes in PCN-553 to allow the use of ZIRLO fuel cladding material.
08/26/2004 2003-11-001 Schedule for Submittal of Generic Control Room Habitability NRC Generic Letter SCE to NRC LTR 2003-01, "Control Room Habitability" SCE will submit a proposed TS change 11/26/2003 within 90 day 2003-08-005 To ensure that the San Onofre Units 2 and 3 technical specifications verify the SCE to NRC LTR integrity of the*CRE and the assumed in leakage rates of potentially contaminated 08/05/2003 air, SCE will submit a License Amendment Request (LAR) to revise TS 3.7.11 by December 9, 2003 (i.e., within 180 days after the issuance of Generic Letter 2003-01). The revised TS 3.7.11 will include surveillance requirements to verify CRE integrity and to confirm that the CRE in leakage rates assumed in the design basis radiological and hazardous chemical analyses are greater than tested in leakage rates. The revised TS 3.7.11 and all necessary modifications to the CRE to demonstrate compliance with the revised TS 3.7.11 would be implemented within 60 days after the completion of baseline in leakage testing described in the responses to Items (l)(a) and (l)(b), or within 60 days of approval of the LAR, whichever is later.
2003-08-004 To ensure that the most limiting in leakage into the CRE is considered in the SCE to NRC LTR hazardous chemical analyses, SONGS U2 & U3 will perform CRE inleakage testing. 08/05/2003, Page 10 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 2003-08-003 SCE will revise the radiological analyses to model a greater inleakage value and SCE to NRC LTR perform CRE in leakage testing. Increasing the in leakage value will provide a 08/05/2003 more realistic acceptance criterion for in leakage testing. The revised analyses and CRE in leakage testing will be completed prior to the Unit 3 Cycle 13 outage that is currently scheduled to begin in September 2004. Following the completion of in leakage testing, SCE will submit a letter describing how and when the analyses, tests, and measurements were performed and the results of the testing in order to demonstrate whether the most limiting in leakage into the CRE is no more than the value assumed in the revised design basis radiological analyses for control room habitability.
2003-08-002 SCE will submit a letter by December 9, 2003 (i.e., within 180 days after the SCE to NRC LTR issuance of Generic Letter 2003-01) to describe the applicable habitability 08/05/2003 regulatory requirements (e.g., GDC 1, 3, 4, 5, and 19) for the San Onofre Units 2 and 3 control rooms and how the Control Room Habitability Systems (CRHSs) are designed, constructed, configured, operated, and maintained in accordance with the facility design and licensing bases.
2003-02-001 On February 11, 2003, the NRC issued an immediately effective order establishing SCE to NRC L TR interim inspection requirements for reactor vessel heads at pressurized water 02/14/2003 reactors (Reference 3). By March 3, 2003, SCE will respond to this order in the context of the future inspections of the San Onofre Unit 2 and 3 reactor vessel heads at their next refueling outages.
2002-12-001 SCE is committing to notify the SONGS NRC Project Manager prior to completing SCE to NRC LTR the UT inspection if SCE does not achieve an inspection scope of one inch above 12/31/2002 the indicated top of the weld., Page 11 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 2002-04-002 SCE will perform either qualified volumetric inspection, or a qualified wetted SCE to NRC LTR surface inspection on all of the 102 RPVH penetrations. The inspection 04/02/2002 techniques that will be applied to the inside diameter of the RPVH penetrations have been successfully demonstrated on the EPRI mock-ups that were constructed in support of Generic Letter 97-01. SCE will apply the acceptance criteria contained in a letter from the NRC staff to the Nuclear Energy Institute (NEI) 2002-04-001 SCE plans to perform an effective visual inspection of 100 percent power of the SCE to NRC LTR RPVH nozzle penetrations that is capable of detecting and discriminating small 04/02/2002 amounts of boric acid deposits from nozzle leaks.
2001-01-003 SCE has established the capability to monitor radioactive iodine that have been SCE to NRC LTR released to offsite environs. This capability is described in our site procedures.
01/11/2001 The capability to monitor radioactive iodine is considered a regulatory commitment.
2001-01-002 The capability for classifying fuel damage events at the Alert level threshold has SCE to NRC LTR been established for San Onofre at radioactivity levels of 300 mCi/gm dose 01/11/2001 equivalent iodine. This capability is described in emergency plan implementing procedures and has been implemented. The capability for classifying fuel damage events is considered a regulatory commitment.
2000-07-001 SCE is committing to measure total CEA group worth of at least 3000 pcm each SCE to NRC LTR-refueling outage.
7/07/2000 2000-03-001 SONGS commits to monitor the impact of the Proposed AOT Change. The risk-SCE to NRC L TR informed TS change will be implemented consistent with the SONGS TS 03/30/2000 requirements and using the Configuration Risk Management Program as documented in plant procedure S023-XV-SO., Page 12 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1999-09-005 SCE will develop and proceduralize a schematic to determine an MOV test SCE to NRC LTR interval that is based on IDP final risk ranking, available valve margin, and valve, 9/28/1999 performance history. The schema will be comprised of an evaluation of risk ranking, relative margin, and group as well as individual value performance.
1999-09-004 Work toward the development of a mitigation technique.
SCE to NRC LTR 09/24/1999 1999-09-003 Keep the NRC informed of the future plans for eddy current exams at U3 on a SCE to NRC LTR cycle by cycle basis 09/24/1999 1999-09-002 Perform visual inspections of the periphery reactor vessel head penetration SCE to NRC LTR nozzles during each refueling outage for both U2 and U3 09/24/1999 1999-09-001 Maintain the commitment to perform eddy current examinations of 100% of the SCE to NRC LTR reactor vessel head penetrations at San Onofre Unit 3 at a time that meets the 09/24/1999 objectives stated above 1999-07-001 SCE will provide the results of the pressure-locking thrust prediction SCE to NRC LTR 07 methodology to the NRC along with any recommended actuator margin 07/21/1999 requirements, any limitations associated on the use of the methodology and any diagnostic test equipment accuracy considerations by December 15,1999.
1999-01-004 Work toward the development of a mitigation technique.
SCE to NRC 01/13/1999 1999-01-003 Keep the NRC informed of future plans for eddy current exams at U3 on a cycle SCE to NRC by cycle basis 01/13/1999 1999-01-002 Continue to perform visual inspection of periphery reactor vessel head I
SCE to NRC penetration nozzles during each refueling outage for U2 and U3.
01/13/1999 1999-01-001 Perform eddy current exams of 100% of reactor vessel head penetrations at U3 SCE to NRC at an appropriate time.
01/13/1999, Page 13 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1997-10-002 Current information for San Onofre Units 2 and 3 will be provided to confirm the SCE to NRC LTR adequacy of the net positive suction head (NPSH) available for emergency core 10/24/1997 cooling (including decay heat removal) and containment heat removal pumps.
1997-10-001 As requested in Generic Letter (GL) 97-04, Southern California Edison (SCE) will SCE to NRC LTR submit the information requested in GL 97-04 by January 5, 1998.
10/24/1997 1997-08-001 Edison is committing to perform inspections of the Unit 3 Vessel Head SCE to NRC LTR Penetration (VHP) nozzles during the Unit 3 Cycle 10 refueling outage.
08/06/1997 1997-03-003 All valve factor dependent valves (i.e., gate valves) within the program SCE to NRC LTR population considered to have a low thrust and/or valve factor margin will be 03/13/1997 fully stroked dynamically (if practicable) at an interval no greater than three refueling cycles. The diagnostic test equipment utilized should provide a quantitative verification of the motor actuator output thrust and torque as well as system parameters of pressure and flow (if available) in order to provide a basis for determining valve factor. Results of the dynamic testing will be evaluated by the MOV Test Data Reconciliation Procedure.
1997-03-002 All safety-related MOVs within the GL 89-10 MOV program scope will be fully SCE to NRC LTR stroked statically at an interval no greater than three refueling cycles with a 03/13/1997 diagnostic device that provides a quantitative verification of the motor actuator thrust and/or torque output. This testing will be performed in conjunction with the scheduled periodic maintenance activities on the valves and includes (when possible) an as-found and as-left test. Results of the static testing will be evaluated by the MOV Test Data Reconciliation Procedure., Page 14 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1997-03-001 A surveillance test of all safety-related MOVs within the GL 89-10 MOV program SCE to NRC LTR scope will be performed at an interval no greater than one refueling cycle.
03/13/1997 Verification of each valve to successfully complete a full open and close stroke will be provided as a result of this test and documented as part of the current In Service Testing Program.
1997-02-007 For those penetrations which rely on relieving paths with intervening valves, SCE to NRC LTR specific administrative controls will be implemented to ensure that these valves 02/03/1997 will remain open throughout Modes 1 through 4, or that compensatory measures are taken to provide* overpressure protection in the event of their closure. The proce_dures for both Units 2 and 3 will be revised prior to returning Unit 2 to service from the current refueling outage. These procedures will be fully implemented at Unit 2 prior to returning Unit 2 to service from the current refueling outage. The Unit 3 procedures that require containment entry, or are associated with design changes, will be implemented by the end of the next refueling outage, which is currently scheduled to start on April 12, 1997.
1997-02-006 The five penetrations in each unit which require modification will be upgraded SCE to NRC LTR during each unit's cycle 9 refueling outage. The modifications consist of adding 02/03/1997 thermal insulation on Penetrations 42 and 43, removing and modifying thermal insulation on Penetrations 45 arid 46, and adding a relief valve an the piping inside containment for Penetration 11. These physical changes will be completed at Unit 2 prior to return to service from the current refueling outage and at Unit 3 before the unit is returned to service from the next refueling outage, which is currently scheduled to start or April 12, 1997., Page 15 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1997-02-005 Relief valves that are being credited to protect penetrations from overpressure SCE to NRC LTR will be added to the lnservice Testing (1ST) program by the end of the next Unit 3 02/03/1997 refueling outage, which is scheduled to begin on April 12, 1997. All required testing in accordance with the 1ST program will be complete at Unit 2, as practical, prior to the return to service from the current refueling outage and at Unit 3 during the next refueling outage, which is scheduled to begin on April 12, 1997. As stated in the report, Edison will approve all calculations prior to returning Unit 2 to service from the current refueling outage. These calculations will be maintained onsite, available for review. We will inform the NRC if our conclusions or our proposed corrective actions change.
1997-02-004 Procedural changes are being made to ensure that containment penetrations are SCE to NRC LTR not isolated from credited relief paths without compensating actions. The 02/03/1997 procedures for both Units 2 and 3 will be revised prior to returning Unit 2 to service from the current refueling outage. These procedures will be fully implemented at Unit 2 prior to returning Unit 2 to service from the current refueling outage. The Unit 3 procedures that require containment entry, or are associated with design changes, will be implemented by the end of the next refueling outage, which is currently scheduled to start on April 12, 1997.
1997-02-003 Four of the remaining five penetrations and their respective piping systems, SCE to NRC LTR although they are demonstrated to be operable ba*sed on accumulated leak rate 02/03/1997 testing data, require changes in insulation to eliminate the need to take credit for valve leakage. These modifications will be completed in Unit 2 prior to the return to service from the current refueling outage and will be completed in Unit 3 during the next refueling outage, which is scheduled to begin on April 12, 1997.
1997-02-002 Enhancements to the Emergency Operating Instructions for both Units 2 and 3 SCE to NRC LTR will be implemented prior to returning Unit 2 to service from the current 02/03/1997 refueling outage., Page 16 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1997-02-001 A design change to delay the restart of the ECUs following a safety injection SCE to NRC LTR actuation signal has been implemented in Unit 2 and will be implemented in Unit 02/03/1997 3 during the Cycle 9 refueling outage, which is scheduled to begin on April 12, 1997.
1997-01-001 Edison will submit the 120 day response by February 4, 1997.
SCE to NRC LTR GL96-06 01/28/1997 1996-11-001 Edison will review the current MOV verification program to determine if any SCE to NRC LTR changes are appropriate based on GL 96-05 and will submit a written summary 11/14/1996 description of the MOV periodic verification program by March 17, 1997.
1996-10-002 If piping systems that penetrate the containment are susceptible to thermal SCE to NRC LTR expansion of fluid so that overpressurization of piping could occur.
10/30/1996 1996-10-001 If containment air cooler cooling water systems are susceptible to either SCE to NRC LTR waterhammer or two-phase flow conditions during postulated accident 10/30/1996 conditions 1996-05-001 Having the ability to perform the 480V transformer replacement during plant SCE to NRC LTR operation would be cost effective. Therefore, Edison will be requesting approval 05/14/1996 of this change as a Cost Beneficial License Action.
1996-04-006 The review and modification of surveillance procedures, as necessary, for SCE to NRC LTR complete testing to comply with the TS will be completed for Units 2 and 3 prior 04/18/1996 to startup from the SONGS Unit 2 Cycle 10 refueling outage and prior to the SONGS Unit 3 Cycle 9 refueling outage, respectively.
1996-04-005 All channels of reactor protective system and ESF actuation logic for one unit will SCE to NRC LTR be reviewed.
04/18/1996 1996-04-004 Third-of-a-kind (or swing) pump and valve logic will be reviewed for one unit.
SCE to NRC L TR 04/18/1996, Page 17 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1996-04-003 Where dual tn redundancy occurs, one tn will be reviewed.
SCE to NRC LTR 04/18/1996 1996-04-002 The affected systems and procedures for one unit will be reviewed.
SCE to NRC L TR 04/18/1996 1996-04-001 Since San Onofre Nuclear Generating Station {SONGS) Units 2 and 3 have the SCE to NRC LTR same TS, surveillance procedures, and logic for the GL 96-01 affected systems, 04/18/1996 the following review methodology will be used:
1995-04-001 Consistent with our contractual obligations with CE and consistent with the April SCE to NRC LTR 4, 1995 letter that Richard S. Siudek {CE/ABB) sent to William T. Russell {USNRC) 04/17/1995 (Reference 6), Edison will resubmit a response to Generic Letter 92-01 within 30 days after CE has released the relevant proprietary information to Edison on a non-proprietary basis.
1994-02-004 Edison will monitor the wide range pressurizer pressure transmitters on a SCE to NRC LTR refueling cycle interval. This is consistent with Bulletin 90-01, Supplement 1, 02/11/1994 Requested Actions, Operating Reactors I.a. Should this interval exceed 24 months, NRC concurrence will be obtained prior to exceeding the 24 month interval allowed by the bulletin.
1994-02-002 In order to provide a final resolution of this issue, prior to the completion of the SCE to NRC LTR Cycle 8 refueling outage, Edison will: 2) obtain motor specific performance data 02/11/1994 which will then be used as the basis for our GL 89-10 design basis calculations.
1994-02-001 In order to provide a final resolution of this issue, prior to the completion of the SCE to NRC LTR Cycle 8 refueling outage, Edison will: 1) Reanalyze DC MOVs using the Limitorque 02/11/1994 methodology, and/or,, Page 18 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1993-09-003 For MOVs set and tested using the TMD during future refueling outages, a SCE to NRC LTR MOVATS ER 5.2 evaluation will be completed prior to returning the MOVs to 09/30/1993 service. In addition, by the end of the Unit 3 Cycle 8 refueling outage, SCE will complete documentation and validation of new information on MOV diagnostic equipment inaccuracy and evaluations to account for uncertainty in setting operating thrust to ensure operability for all MOVs in the San Onofre Units 2 and 3 GL 89-10 program.
1993-09-002 A TLU calculation will be performed to determine stem and ypke-mounted strain SCE to NRC LTR gage thrust measurement uncertainties.
09/30/1993 1993-09-001 For uncertainties associated with other diagnostic systems, including thrust SCE to NRC LTR measurement using strain gages, SCE will ensure that the uncertainty of those 09/30/1993 systems will be less than the value for diagnostic system uncertainties used in the GL 89-10 setpoint calculation.
1993-03-003 Although SCE believes our enhanced surveillance program is adequate to detect a SCE to NRC LTR failed transmitter, we will complete an evaluation of our enhanced monitoring 03/04/1993 program to verify program adequacy during the preparation of the program procedure. When these actions have been completed, SCE will send the requested notification letter to the NRC.
1993-03-002 A separate procedure for the enhanced monitoring program will be issued by SCE to NRC L TR November 19, 1993.
03/04/1993 1993-03-001 SCE will comply with the actions requested by the NRC for Rosemount Model SCE to NRC LTR 1153 Series B and D, and Model 1154 transmitters manufactured prior to July 11, 03/04/1993 1989 except for the monitoring frequency of category lb transmitters which may exceed the 24 month refueling cycle., Page 19 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1992-09-001 SONGS 1 will be permanently shut down approximately the end of November SCE to NRC LTR 1992 and the reactor subsequently defueled in March 1993. Following defueling, 09/18/1992 the four shutdown functions will no longer be required to achieve and maintain hot shutdown conditions. The spent fuel will be placed in the spent fuel pool for long term decay heat removal, which will be provided by the component cooling water system in conjunction with the salt water cooling system. These changes will take place within the 3 year interval allowed by GL-87-02 to submit the results of USI A-46 review.
1992-01-001 Full compliance will be achieved by September 30, 1992, when both the Units 2 SCE to NRC LTR and-3 ISi programs are formally issued.
01/17/1992 1991-09-003 SCE will provide written confirmation of the completion of items (c) and (d) by SCE to NRC LTR November 15, 1991.
09/30/1991 1991-09-002 The verification and validation of the computer program, in accordance with SCE to NRC LTR Quality Assurance requirements, associated with the process described in item 09/30/1991 (b) above will be completed by January 17, 1992.
1991-06-002 Full compliance, regarding parking lot 1, will be achieve by August 30, 1991, when SCE to NRC LTR the NCRs are dispositioned.
06/25/1991 1991-06-001 Full compliance will be achieved at the next annual update of the UFSARS.
SCE to NRC LTR 06/10/1991 1991-01-001 For item 4, our Human Factors review of the CFMS displays has determined that SCE to NRC LTR use of cyan instead of white would provide a greater improvement in the CFMS 01/31/1991 level 1 display. This change will also be completed during the Unit 2, Cycle 6 refueling outage.
1990-12-004 While we plan to comply with the applicable items, we are confirming our SCE to NRC LTR compliance with each recommendation and will provide a detailed response 12/27/1990 when we submit the amendment application., Page 20 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1990-12-003 We will integrate the Technical Specification changes requested by GL 90-06 with SCE to NRC LTR that submittal.
12/27/1990 1990-12-002 This TS change submittal will be made by the end of the Unit 2 Cycle 6 refueling SCE to NRC LTR outage scheduled for July to September 1991.
12/21/1990 1990-12-001 As requested in GL 90-06, this TS change submittal will be made by the end of the SCE to NRC LTR Unit 2 Cycle 6 refueling outage scheduled for July to September 1991.
12/21/1990 1990-08-008 We intend to provide the results from the loss of normal instrument air testing SCE to NRC LTR (3.2a), the review of the blowdown inspection program (1.2c), and the review of 08/30/1990 valve post-installation testing (3.2b) by November 30, 1990. The results from the air quality laboratory tests (1.2a) and the Instrument Air System flowrate measurements (3.2c) will be provided to you within six months of return to service from the Cycle 11 refueling outage. Finally, the resolution of the verification of an isolated incident of residual desiccant (1.2b) will be provided to you by the end of the Cycle 12 refueling outage.
1990-08-007 Based on this data an appropriate system flowrate will be determined and the SCE to NRC LTR FSAR will be updated as appropriate. We will provide you with the results within 08/30/1990 six months after return to service from the Cycle 11 refueling outage.
1990-08-006 A review of the post-installation test records will be conducted to verify that all SCE to NRC LTR testing meets current post-installation standards. We will provide you with the 08/30/1990 results of the review by November 30, 1990.
1990-08-005 The testing is scheduled for completion by November 1990. We will provide you SCE to NRC LTR with the final test results by November 30, 1990.
08/30/1990 1990-08-004 In response to the generic letter, we will review our inspection program and SCE to NRC LTR provide the results of our review to you by November 30, 1990.
08/30/1990, Page 21 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1990-08-003 A follow-up Cycle 12 refueling outage inspection will be performed to confirm SCE to NRC LTR this conclusion. We will inform you of the results of the inspection at the end of 08/30/1990 the Cycle 12 refueling outage.
1990-08-002 In order to reconfirm our conclusion, we will perform laboratory tests of the air SCE to NRC LTR quality. To ensure that the air quality testing is performed during normal system 08/30/1990 operating loads and configuration, the air quality testing will be performed after startup from the Cycle 11 refueling outage. We will provide you with the results of the air quality tests within six months after return to service from the Cycle 11 refueling outage.
1990-08-001 SCE will submit the MCCB testing report for Unit 1 in accordance with the SCE to NRC L TR schedule restated above. Following submittal ofthe Unit 1 report, SCE will have 08/21/1990 satisfied all of the reporting requirements of NRC Bulletin 88-10.
1990-07-002 SCEs response to Generic Letter 90-04 will be completed by the NRC due date of SCE to NRC LTR September 23, 1990.
07/03/1990 1990-07-001 As requested by Generic Letter 89-13, SCE will provide a single written SCEto NRC LTR confirmation to the NRC (within 30 days of completion) that the actions required 01/26/1990 by Generic Letter 89-13 have been completed for each Unit. Following submitta'I of this verification, all action for this item will be complete.
1990-03-007 Overfill and other transient uncertainties will be explicitly addressed within the SCE to NRC LTR IPE. Thus a more complete understanding of plant safety and appropriate plant 03/20/1990 specific modifications to improve overall plant safety can be obtained. SCE will submit the results of our IPE by September 1, 1992 1990-03-006 The consolidated NRC open item and commitment tracking program will be SCE to NRC LTR implemented by June 1, 1990. Review of NRC commitments and tracking 03/19/1990 program documentation will be completed by August 1, 1990., Page 22 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1990-03-005 For those licensees which elect not to implement the recommendations, an SCE to NRC LTR appropriate justification is required. SCE will provide a response by March 20, 03/19/1990 1990. Therefore, USI A-47 is not resolved for SONGS 2 and 3.
1990-03-004 Emergency lighting modifications will be implemented if required as a result of SCE to NRC LTR 580 procedures.
03/12/1990 1990-03-003 SCE will develop a severe weather response procedure in accordance with SCE to NRC LTR NU MARC 87-00.
03/12/1990 1990-03-002 Consistent with SCEs Station Blackout analysis, SCE will modify plant procedures SCE to NRC LTR to require load group A to be connected to battery C and load group B to be 03/12/1990 connected to battery D during a Station Blackout event.
1990-03-001 The installation of cable and conduit between DC Buses A and C and DC Buses B SCE to NRC LTR and D will be implemented to comply with the SBO rule.
03/12/1990 1989-11-005 These corrections will be submitted as an additional supplement to the original SCE to NRC LTR SCE response. SCE will submit the additional supplement by March 1, 1990. That 11/16/1989 supplement will provide a revised summary of nontraceable stored spares contained in Appendix A of the original SCE response. SCE expects the population of nontraceable MCCBS to be reduced.
1989-11-004 For station applications which require an obsolete model or instances of SCE to NRC LTR corrective maintenance in which SCE has not yet obtained traceable products, 11/16/1989 SCE will continue to maintain sufficient stored spares utilizing nontraceable MCCBs which have been satisfactory tested. However, contrary to the original SCE response, access to these MCCBs will be controlled and limited to serve short term measures. For each occurrence of use, the MCCB will be evaluated for operability and resolved for the long term per Station NCR Procedure S0123-XV-
- 5. SCE will ensure that all reasonable courses of action are evaluated before proceeding with the use of a nontraceable MCCB., Page 23 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1989-11-003 In compliance with the NRC position, SCE will retain nontraceable MCCBs in SCE to NRC LTR quarantine.
11/16/1989 1989-11-002 Acceptability will include MCCBs in which SCE had previously been unable to SCE to NRC LTR establish traceability by QA audit of verifiable documentation. Additional 11/16/1989 traceability investigations as performed by SCE QA audit will not be required. SCE will document acceptability in accordance with Station NRC Procedure S0123-XV-5 and report its findings as a supplement to the original SCE response.
I 1989-11-001 Based on the clarification offered by this NRC position for MCCBs received prior SCE to NRC LTR to August, 1983, SCE will designate each MCCB which is traceable to an original 11/16/1989 construction order as acceptable.
19&9-10-004 SCE will be installing isolation valves and test connections in the instrument air SCE to NRC LTR backup nitrogen system to allow testing of the backup nitrogen system isolation 10/30/1989 check valves during the Cycle 5 refueling outages for Units 2 and 3 (Unit 2 is currently in its Cycle 5 refueling outage; Unit 3 is scheduled to begin its Cycle 5 refueling outage in April 1989}. Consistent with the requirements of Generic Letter 88-14, SCE will submit notification to the NRC when these modifications have been completed.
I 1989-09-001 In response to Bulletin Action Request 5, SCE will be replacing or testing all SCE to NRC LTR installed CBs that cannot be traced to the Circuit Breaker Manufacturer before 09/06/1989 startup from the first refueling outage beginning after March 1, 1989. In response to Reporting Requirement 2 which requests submittal of these Action 5 test results, SCE will provide separate reports for Units 1, 2 and 3. Thereport for San Onofre Unit 1 will be submitted 30 days after startup following the Cycle 11 outage. For Units 2 and 3, the reports will be submitted within 30 days after their Cycle 5 outages.
1989-07-001 SCE will reduce the occurrence of out of range data by January 1, 1992.
SCE to NRC L TR Additionally, as required by Generic Letter 89-06, SCE will retain the completed 07/14/1989 checklist and photographs for CFMS for at least three years., Page 24 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1989-06-006 SCE commits to comply with the Actions Requested Item 2 of Reference 1, but SCE to NRC LTR reserves the right to propose alternative actions with supporting justification 06/19/1989 prior to the next San Onofre Unit 1 refueling outage.
1989-04-005 Minor changes will be made as necessary to ensure operation of this system SCE to NRC LTR under the conditions of a station blackout event.
04/17/1989 1989-04-004 Minor procedure changes will be implemented in the SBO response procedure to SCE to NRC LTR ensure all of the Provisions of NU MARC 87-00, Section 7 are included.
04/17/1989 1989-04-003 San Onofre Unit 1 currently has an SBo response procedure, SOl-1.0-60. This SCEto NRC LTR procedure will be reviewed and modified as necessary to satisfy the 04/17/1989 requirements of NUMARC 87-00, Section 4.2.1.
1989-04-002 SCE will develop a severe weather response procedure in accordance with SCE to NRC LTR NU MARC 87-00, Section 4.2.3.
04/17/1989 1989-04-001 In the event that San Onofre Unit 1 becomes blacked out, actions necessary to SCE to NRC LTR restore power to the switchyard would be fulfilled by Unit 2/3 operators. This 04/17/1989 procedure will be reviewed. and modified as necessary to meet NU MARC 87-00, Section 4.2.2.
1989-03-006 Consistent with Reporting Requirement 2 of Bulletin 88-10, SCE will submit a SCE to NRC LTR report that summarizes the results of tests conducted in accordance with Action 03/30/1989 Requests 3 and 5 within 30 days after start-up from the Unit 1 Cycle 11, Unit 2 Cycle 5 and Unit 3 Cycle 5 refueling outages.
1989-03-003 as required by NRC Bulletin 88-11 Reporting Requirement 3, SCE will provide the SCE to NRC LTR NRC with the results of the plant specific analysis required by NRC Bulletin 88-11 03/08/1989 Action Item l.d by February 4, 1991.
1989-03-002 Actual plant data will be used to define loading conditions for input to the fatigue SCE to NRC LTR and stress evaluations consistent with Requested Action l.d of NRC Bulletin 88-03/08/1989
- 11., Page 25 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1989-03-001 The CEOG will perform a preliminary bounding evaluation of CEOG surge lines SCE to NRC LTR using actual data collected from CEOG plants by July 1, 1989. This activity will 03/08/1989 address the intent of Requested Action 1.b. After July 1, 1989, this preliminary bounding evaluation will be available to CEOG member utilities.
1989-02-011 Based on this evaluation, it has been concluded that the use of permanent tags SCE to NRC LTR which uniquely distinguish the first isolation valve off the RCS/SDCS will be 02/21/1989 installed. The existence of these tags will be incorporated into plant operating procedures and the significance of these tags and values will be taught to Maintenance and other support personnel prior to entering a Reduced Inventory Condition.
1989-02-009 As discussed in our response to item 2.5 of the expeditious actions, prior to SCE to NRC LTR entering an RCS Reduced Inventory Condition, RCS perturbation control will be 02/21/1989 implemented. An initial RCS Perturbation List will be established by reviewing "in progress" surveillance, procedures, and Work Authorizations to determine their potential threat to the RCS stability. In addition, management approval will be required for all Work Authorizations which may impact reduced inventory or mid-loop operation. SCE policy is to delay such activities (whenever possible) until the RCS is not in a Reduced Inventory Condition. However, when such activities are identified and cannot be delayed, then extra measures will be taken as appropriate to the degree of threat. These measures will include actions to mitigate the loss of Reactor Core Cooling and/or enhanced monitoring of criti parameters.
1989-02-008 The Combustion Engineering Owners Group (CEOG) is investigating the impact of SCE to NRC LTR the generic letter with respect to Technical Specification requirements. Based on 02/21/1989 preliminary results of their work to date, certain areas have been identified as potantially being affected by the actions identified by the generic letter.... SCE will follow this effort closely and will submit changes to techni specifications where warranted to achieve the desired relaxation., Page 26 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1989-02-007 Areas which SCE intends to analyze are the following: i) Determination of hot leg SCE to NRC LTR vent path size versus number of days elapsed since plant shutdown. ii) 02/21/1989 Determination of required makeup water flow requirements versus number of days elapsed since plant shutdown. iii) Determination of loss of OHR RCS heatup rate. iv) Determination of loss of DHR containment pressurization rate v) Confirm adequacy of the fuel transfer tube water seal to maintain containment integrity vi) Determination of minimum OHR flow requirements vii) Analysis of removal of high pressure closure contacts to the OHR suction valves viii) Analysis to develop a basis for RCS level instrumentation installation and response (i.e., RCS level gradient correlation. These planned analyses will be completed in sufficient time to permit any procedural enhancements and plant modifications required by the analyses to be completed by April 30, 1990 and the end of the Cycle 6 refueling outage, respectively.
1989-02-006 The Loss of Shutdown Cooling procedure will provide guidance to ensure makeup SCE to NRC LTR flow does not bypass the Reactor Core.
02/21/1989 1989-02-005 Adequate operating, operable and/or available equipment of high reliability is SCE to NRC LTR provided for cooling the RCS and for avoiding a loss of RCS cooling. Prior to 02/21/1989 entering an RCS Reduced Inventory Condition, two means of adding inventory to the RCS will be required. This will be accomplished by having one High Pressure Safety Injection Pump operable and either a Containment Spray Pump, second High Pressure Safety Injection Pump, or Changing Pump available. In order to prevent Reactor Core uncovery, use of a Charging Pump will be time dependent after shutdown because of its lower flowrate. Use of a Containment Spray Pump will require that an operator be dispatched to the Pump for value manipulation., Page 27 of 54
Commitment Number
'Verbatim Commitment to NRC Commit Source 1989-02-004 SCE has developed and implemented procedures which describe activities SCE to NRC LTR conducted during RCS dndown modes and operation with the RCS partially filled. 02/21/1989 A summary listing of those procedures is presented below: S023-5-1.5, Plant Shutdown form Hot Standby to Cold Shutdown S023-3-2.6, Shutdown Cooling System Operation S023-3-1.8, Dning the Reactor Coolant System S023-5-1.8, Shutdown Operations (Modes 5 and 6) S023-3-2.8.l, Refueling Cavity Dning Operations S023-5-1.3, Plant Startup from Cold Shutdown to Hot Standby S023-3 1.4, Filling and venting the Reactor Coolant System AOI S023-13-15, Loss of Shutdown Cooling In addition, a number of planned actions to address the expeditious actions of the generic letter issues, will be incorporated into the RCS dn procedure prior to initial dning of the RCS to a reduced inventory condition as specified in our response to the expeditious actions.
1989-02-003 Annunciation, both audible and visual will be provided for the following abnormal SCE to NRC LTR conditions: i) RCS low level ii) RCS high temperature iii) DHR low flow iv) Low DHR 02/21/1989 motor amperes 1989-02-002 Two independent temperature indications of reactor core exit conditions will be SCE to NRC L TR in operation prior to entering an RCS mid-loop condition whenever the Reactor 02/21/1989 Vessel (RV) head is located on top of the RV.
1989-02-001 Two independent, continuous, full range RCS water level indications with low SCE to NRC LTR level alarm capability will be provided in the control room. Both indications will 02/21/1989 be in service in the control room whenever the RCS is in a reduced inventory condition.
1989-01-015 The Loss of Shutdown Cooling procedure will provide guidance to ensure makeup SCE to NRC LTR flow does not bypass the Reactor Core.
01/05/1989, Page 28 of 54
Commitment Number Verbatim Commitment to NRC 1989-01-014 Prior to entering an RCS Reduced Inventory Condition, two means of adding inventory to the RCS will be required. This will be accomplished by having one HPSI Pump operable and either a Containment Spray Pump or Charging Pump available. In order to prevent Reactor Core uncovery, use of a Charging Pump will be time dependent after shutdown because of its lower flowrate. Use of a Containment Spray Pump will require that an Operator be dispatched to the pump for valve manipulation.
1989-01-013 Programmed Enhancements will include an evaluation to determine if it would be beneficial to tag the first isolation valve off the RCS/RH RS which could potentially dn the RCS to state that misoperation of this valve may result in a loss of RCS inventory.
1989-01-012 The RCS Perturbation List will be maintained current by reviewing daily revisions to the Work Authorization Letter and all other activities within the cognizance of the operating shift. Those activities which cannot be delayed will be included on the list as previously described.
1989-01-011 Prior to entering an RCS Reduced Inventory Condition, RCS Perturbation control will be implemented. An initial RCS Perturbation List is established by reviewing "in progress" surveillances, Procedures, and Work Authorizations to determine their potential threat to RCS stability. Additionally, management approval will be required for all Work Authorizations which may impact reduced inventory or mid loop operation. SCE policy is to delay such activities (whenever possible) until the RCS is not in a Reduced Inventory Condition. However, when such activities are identified and cannot be delayed, then extra measures will be taken as appropriate to the degree of threat. These measures will include actions to mitigate the loss of Reactor Core cooling and/or enhanced monitoring of criti parameters.
1989-01-010 Programmed Enhancements will include an evaluation for providing a second continuous indication of RCS water level., Page 29 of 54 Commit Source SCE to NRC LTR 01/05/1989 SCE to NRC LTR 01/05/1989 SCE to NRC L TR 01/05/1989 SCE to NRC LTR 01/05/1989 SCE to NRC LTR 01/05/1989 I
I
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Commitment Number Verbatim Commitment to NRC Commit Source 1989-01-009 While in the mid loop condition, with HJTC No. 6 uncovered or inoperative, LPSI SCE to NRC LTR pump amperage will be monitored and recorded hourly in the control room, until 01/05/1989 such Instrumentation has been provided with alarm capability.
1989-01-008 Prior to entering a Reactor Coolant System Mid loop Condition, two independent SCE to NRC LTR continuous temperature indications of Reactor Core exit conditions will be in 01/05/1989 operation. The selected indications will be the water covered unheated thermocouples of the Heated Junction Thermocouple (HJTC) System or the Core Exit Thermocouples addressed on the plant Qualified Safety Parameter Display System {QSPDS) Computer in the Control Room. For reliability, the selected indications will be energized from separate power supplies. When Reactor Head disassembly or reassembly is in progress, temporary cables will be provided to the selected thermocouples. The available temperature indications will be monitored and recorded hourly in the control room, until such instrumentation has been provided with alarm capability.
1989-01-007 In addition, the Maintenance Department will signoff that the planned SCE to NRC LTR Containment Closure methods conform to the definition of a Closed 01/05/1989 Containment. Material such as wood and plastic sheeting will be specifily excluded from use as closure methods, unless specifily allowed by an engineering evaluation that considers the potential effects of containment internal pressurization and combustion.
1989-01-006 Cold Leg valve openings will meet the same requirements as maintenance SCE to NRC LTR openings, or will be administratively controlled when such openings are greater 01/05/1989 than one square inch. Operation of the RCS Educator System (to decrease activity and hydrogen levels) requires the opening of Cold Leg vent values with an aggregate area of two to three square inches. If the evolution must be performed when the containment is not closed and a valid hot leg vent does not exist, then an operation will be continuously stationed inside the containment to close these values within 20 minute notice., Page 30 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1989-01-005 Valid hot leg vents include the pressurizer manway and the steam generator hot SCE to NRC LTR leg mariway provided these vent paths are unobstructed. Other hot leg vents will 01/05/1989 be excluded, unless specifily allowed by an engineering evaluation that considers decay heat and hot leg pressurization. To avoid entering the 45 minutes requirement, procedures will have the option of administratively limiting RCS Cold Leg vent size to less than one square inch until a Hot Leg vent is established.
1989-01-004 Prior to entering an RCS Reduced Inventory Condition, Containment Closure SCE to NRC LTR control will be implemented as stated in the Existing Actions, but with new 01/05/1989 requirements. With cold leg openings of one square inch or less, Containment Closure will be required within 45 minutes of notice, unless a valid hot leg vent path has been established. If a valid hot leg vent path has been established, then with a cold leg opening of greater than one inch, containment closure will be required within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of initiation.
1989-01-003 Prior to enterin~ an RCS Reduced Inventory Condition,...... [see NRCT 1989 SCE to NRC LTR 003]... In addition, selected Maintenance personnel, and other support personnel 01/05/1989 when applicable, will be trained in the requirements and methods of Containment Closure. The frequency of this training will be the same as that for plant Operators.
1989-01-001 The existing actions are incorporated in the reactor coolant system (RCS) dn SCE to NRC LTR procedure and the planned actions will be incorporated prior to initial dning of 01/05/1989 the RCS to a reduced inventory condition. SCEs response to the programmed enhancements will be submitted under separate cover by February 1, 1989.
1988-10-002 Based on the review, the welds, heat-affected zones and high stress locations, SCE to NRC LTR including geometric discontinuities, of the piping section which will not be 10/19/1988 removed from the plant will be examined non-destructively as requested in Action 2 of the Bulletin to provide assurance that there are no existing flaws.
These examinations will be completed before the end of the Cycle 5 refueling outage for each of Units 2 and 3., Page 31 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1988-10-001 At the Cycle 5 refueling, as requested in Action 3 of the Bulletin, a modification SCE to NRC L TR will be planned and implemented to assure that the pressurizer auxiliary 10/19/1988 spray/pressurizer spray line will not be subjected to combined cyclic and static thermal and other stresses that could cause fatigue failure the remaining operating life of Units 2 and 3.
1988-07-002 It is anticipated that a schedule for completion of the CEOG effort will be SCE to NRC LTR available within 60 days. Therefore, SCE will provide NRC with a schedule for our 07/26/1988 final response to the subject bulletin in approximately 60 days.
1988-05-004 Use of the existing NCR program will require that all boric acid leakage be SCE to NRC LTR adequately evaluated which may include a formal Root Cause Evaluation, and 05/31/1988 that the identified corrective actions be implemented which could include design changes to minimize sources of leakage and the use of corrosion resistant materials, as necessary.
1988-05-003 Revisions to Station Technical procedures and to the NCR procedure will result in SCE to NRC LTR all identified boric acid leaks being subject to the NCR program. The NCR 05/31/1988 procedure provides for thorough investigation of identified deficiencies, evaluation of their effects and identification of corrective actions. This change will add more formality and an engineering review to the existing process and ensure appropriate priority in the evaluation and elimination of the boric acid leaks. By July 1, 1988 program revisions will ensure that any boric acid leakage discovered will be evaluated and dispositioned using NCR's.
1988-05-002 These visual inspections have proven to be effective in identifying boric acid SCE to NRC LTR leakage. Procedure revisions will be written to formalize the existing inspection 05/31/1988 points. Procedures will identify specific areas to be visually inspected, and where necessary, provide detailed guidance regarding obscure locations within an area.
Procedure revisions will be in place by September 1988, in time for the next refueling outage for each unit., Page 32 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1988-05-001 As identified in the enclosure, SCE relies heavily on existing practices to address SCE to NRC LTR boric acid leakage. By July 1, 1988 a revision will be made to the 05/31/1988 Nonconformance Report (NCR) program to address boric acid leakage. This revision will ensure that any boric acid leakage discovered will be documented and dispositioned using the NRC program. Additionally, by September 1988, the Station Technical organization will implement a procedure which will formalize and integrate practices related to boric acid leakage control.
1988-04-001 SCE will formalize and implement an enhanced primary-to-secondary leak rate SCE to NRC LTR monitoring program upon return to service from the present mid-cycle outage 04/06/1988 (tentatively scheduled for April 29, 1988). The enhanced monitoring program will meet the criteria for being able to monitor a tube failure with leakage characteristics similar to that which occurred at North Anna and take appropriate actions prior to rupture of the tube. The following provides details of the San Onofre Unit 1 enhanced monitoring program.
1986-07-001 A search of this COPE listing is made for all quality affecting, including safety SCE to NRC LTR related, equipment purchase orders. If these switches should be determined to 07/28/1986 on a purchase order, the purchase order will be rejected or specific control will be implemented to assure the switch would only be used in the present application.
1986-03-003 SCE commits to inclusion of breaker response time for undervoltage trip into a SCE to NRC LTR periodic trending program. Breaker response time for undervoltage trip will be 03/25/1986 trended on a monthly Interval by SCE NSSS Electrical Engineering. The response time plot will be used in adjusting the maintenance interval. By the letter dated May 2, 1983, from D. G. Eisen hut to R. Dietch and G. D. Cotton, this maintenance interval cannot exceed 6 months.
1986-03-002 If degradation in bearing performance is detected, insomuch as effecting breaker SCE to NRC LTR performance, the bearings will be replaced.
03/25/1986, Page 33 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1986-03-001 Replacement of the remaining HFA relay in the Unit 2 Auxiliary Building SCE to NRC LTR Emergency Chiller will be completed during the current Unit 2 refueling outage.
03/17/1986 1985-12-001 The NRC staff has expressed some concern over the magnitude of the predicted SCE to NRC LTR fuel failures. In response, the event will be reanalyzed taking credit for a Variable 12/05/1985 Overpower Trip (VOPT) from the CPCS.
1985-10-032 The results of the analysis of the increase in feed water flow event indicate that SCE to NRC LTR 10 minutes is not available for operator action to terminate the event. Corrective 10/04/1985 measures will be identified by January 31, 1986 and any modifications will be scheduled in accordance with the Integrated Living Schedule.
1985-10-031 SCE will install modifications during the upcoming outage to assure the capability SCE to NRC LTR of shutting down in the event of a fire.
10/04/1985 1985-10-030 Details of the temperature monitoring program will be submitted by December SCE to NRC LTR 16, 1985.
10/04/1985 1985-10-029 A reliability evaluation of the SWC System will be performed by May 1, 1986.
SCE to NRC L TR 10/04/1985 1985-10-028 SCE agrees that the Independence of these valves will be verified as part of the VI SCE to NRC LTR 7.C.2 analysis. This will be complete by May 1, 1986.
10/04/1985 1985-10-027 A third tn of auxiliary feedwater will be partially installed during the upcoming SCE to NRC LTR outage as part of the Appendix R backfits. The system will not be automatic and 10/04/1985 fully safety related until additional modifications are performed during the refueling backfit outage for Cycle 10. This modification-has been scheduled in accordance with the ILS.
1985-10-026 The suggested Technical Specifications will be submitted by January 31, 1986.
SCE to NRC LTR 10/04/1985 1985-10-025 Each of the remaining issues will be evaluated for safety significance. The SCE to NRC LTR evaluation will be completed by May 1, 1986.
10/04/1985, Page 34 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1985-10-024 An automatic trip feature will be added to the Safety Injection System to SCE to NRC LTR terminate primary injection on low Refueling Water Storage Tank level. The 10/04/1985 details of the modification have not been determined at this time but will be developed as part of preliminary engineering. This modification will be scheduled In the next Integrated Living Schedule (ILS) update in accordance with the ILS Plan.
1985-10-023 An evaluation of when to close the valves on the refueling water return line will SCE to NRC LTR be complete by May 1, 1986.
10/04/1985 1985-10-021 The provisions to isolate the CCW System lines penetrating containment either SCE to NRC LTR immediately or long after an accident will be evaluated. This evaluation will take 10/04/1985 into account post accident radiation levels and accessibility. This review and changes or additions to any procedures will be implemented by May 1, 1986.
1985-10-019 These lines are included in the seismic reevaluation program. Any identified SCE to NRC LTR modifications will be implemented during the upcoming outage.
10/04/1985 1985-10-018 As stated in our January 19, 1984 letter, the necessary procedures will be in-place SCE to NRC LTR prior to return-to-service from the upcoming refueling outage.
10/04/1985 1985-10-017 The inspection program to be performed coincides with type A testing and will SCE to NRC LTR consist of a v.isual Inspection similar to that performed during the 1982 outage.
10/04/1985 1985-10-016 The proposed OMS Technical Specifications will be revised to require the OMS to SCE to NRC LTR be in operation when necessary to protect the integrity of the RHR system from 10/04/1985 overpressure transients. these revised Technical Specifications will be submitted by January 31, 1986.
1985-10-015 SCE will review the seismic capabilities of the leakage detection systems to SCE to NRC LTR determine which if any should be relied upon immediately following a seismic 10/04/1985 event. If seismic capability cannot be demonstrated, alternate means of detecting leakage immediately following a seismic event will be investigated. The results of this review will be provided by November 30, 1985., Page 35 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1985-10-014 Proposed Technical Specifications will be submitted by January 31, 1986.
SCE to NRC LTR 10/04/1985 1985-10-013 The need for greater sensitivities of the SONGS 1 leakage detection system will SCE to NRC LTR be determined by Topic 111-5.A.
10/04/1985 1985-10-012 The load combinations remaining to be reviewed involve other SEP open issues.
SCE to NRC LTR In each of these Issues the effects of the appropriate load combinations will be 10/04/1985 evaluated. The following load combinations are indicated in NRC letter September 21, 1982 as those necessary under the SEP to demonstrate that structural integrity is maintained. The terms are defined in the above letter.
1985-10-011 The analyses and modifications necessary to complete the Seismic Reevaluation SCE to NRC LTR program at San Onofre Unit I will be complete by return-to-service from the 10/04/1985 refueling/backfit outage scheduled to begin on November 30, 1985.
1985-10-010 SCE will perform an analysis similar to that for Topic 111-5.A above. The revised SCE to NRC LTR analysis will be complete by August 31, 1986.
10/04/1985 1985-10-009 SCE will perform a revised analysis of the effects of high energy line breaks inside SCE to NRC LTR containment. The analysis will take into consideration recent information and 10/04/1985 modifications implemented as part of the seismic reevaluation program and Appendix R Program. It will also consider the effects of breaks on cables. The analysis will be complete by August 31, 1986. As leak-before-break methods are expected to be used in resolving the interaction, any required changes in SONGS 1 leakage detection capabilities will also be determined.
1985-10-008 SCEs ongoing evaluation to resolve section 4.5. Topic 111-2, Wind and Tornado SCE to NRC LTR Loadings, is considering the effects of tornado missiles. The results of that 10/04/1985 analysis will be provided by January 6, 1986.
1985-10-007 Details of the intake structure surveillance program will be submitted by October SCE to NRC L TR 4, 1984. The seawall will be inspected during the refueling/backfit outage 10/04/1985 scheduled to start on November 30, 1985.
1985-10-006 The program will be revised to incorporate the above comments prior to the next SCE to NRC LTR scheduled inspection.
10/04/1985, Page 36 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1985-10-004 It should be noted that the analysis does include an evaluation of the effects of SCE to NRC LTR tornado missiles and is not limited to windspeed effects. The project is ongoing 10/04/1985 and is now expected to be complete by January 6, 1986. The results of SCE's study will be provided at that time.
1985-10-003 The results of the evaluations will be incorporated into the Final Safety Analysis SCE to NRC LTR update required by 10 CFR 50.71. If any modifications or changes to the 10/04/1985 Inspection program at SONGS 1 are deemed necessary due to these evaluations, they will be separately reported to the NRC staff.
1985-10-002 SCE agrees with the NRC staff's proposed resolution of the remaining open issues SCE to NRC LTR and will perform the evaluations of section 4.4 of NUREG-0829, or if it is 10/04/1985 determined that such evaluations are not possible due to missing information or th~t it is not practical to do such evaluations, the safety significance of the component or system in question will be evaluated.
1985-10-001 The dates herein specified for major evaluations will be included in the next SCE to NRC LTR revision of the San Onofre Unit 1 Integrated Living Schedule.
10/04/1985 1985-05-001 During this review, should the Maintenance Supervisory personnel identify any SCE to NRC LTR parameter outside its acceptance criteria, further investigation and corrective 05/14/1985 action will be initiated. Information derived from the analysis is used as a basis for purchasing spare parts and replacing components that show sign of degradation. Accordingly, the technical criteria to be used for evaluating trend data, the frequency of trend data analyses, and effect of its results on periodic maintenance will be consistent with Westinghouse Owners Group recommendations where appropriate.
1985-03-003 A Site Order detailing the COPE Program was issued on February 27, 1985. This SCE to NRC LTR program will be fully implemented by June 1, 1985.
03/29/1985, Page 37 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1985-03-002 A Nonconformance Report was issued for these relays and they will remain SCE to NRC L TR quarantined until conversion kits are received to replace the defective coils and 03/29/1985 related parts.' To prevent disqualified parts from being procured or stocked at the SONGS warehouse, additional administrative controls (as described below) are being developed and will be integrated with the existing controls to assure compliance with Action Item No. 4.
1985-03-001 Of the total of 12 lE HFA series 51/54 relays still in use in Units 2 and 3, none SCE to NRC LTR show signs of deterioration. All of these relays are included in a monthly visual 03/29/1985 surveillance to assure continued operability, and will be replaced with Century Series relays before March 12, 1986.
1984-10-003 Accordingly, SCE will install the independent, redundant pressurization systems SCE to NRC LTR for each pneumatic seal prior to use of each seal as a fluid restraining boundary 10/26/1984 to ensure water shielding over spent fuel. These permanent, redundant pressurization systems, described in the Enclosure 1, are similar to a temporary system which was used when the refueling cavity was flooded during the plant start-up testing.
1984-10-002 A design change will be made to the Diesel's starting and running circuitry to SCE to NRC LTR allow idle starting of the Diesels. This will allow the Diesels to be brought up to, 10/01/1984 and held at an idle to allow warm up and full lubrication of the Diesels prior to bringing them up to their full speed of 900 rpm. Once installed, the idle start will be used for all surveillance and post maintenance starts not specifily requiring a cold fast start. In addition, the Diesel Generators will be idled for cooldown prior to Diesel Generator Shutdown. The schedule for implementation of this proposed design change is currently under evaluation., Page 38 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1984-10-001 As recommended by NRC Generic Letter 84-15, a Technical Specification change SCE to NRC LTR is currently in the final stages of preparation and will be submitted in the near 10/01/1984 future. The change will reduce the frequency of cold fast start surveillances from every 31 days to every 184 days as required per Section 4.8.l.l.2a4 and 4.8.l.l.2a5. This will greatly reduce the number of cold fast starts required to satisfy existing Technical Specification required surveillances.
1984-07-002 In addition, these controls will ensure that the older and problematic HFA relay SCE to NRC LTR coils are not inadvertently used as a replacement part in safety-related 07/30/1984 applications in future maintenance efforts.
1984-07-001 Any relays which are not replaced before the Unit 1 return to service will be SCE to NRC LTR included in a monthly visual surveillance to assure their continued operability and 07/30/1984 will be replaced well before March 12, 1986 as required by this bulletin. If signs of deterioration are found (visible cracks or melting), the relay will be replaced on a high priority basis. If the degree of deterioration is significant (e.g., severe spool cracking) an engineering evaluation will be performed to assess the impact of relay failure in order to justify continued operation. Relays will be cleaned in accordance with approved procedures if necessary.
1984-05-004 The recommended enhancements to NPRDS and SEE-IN will be incorporated and SCE to NRC LTR revisions included as appropriate by January 1, 1986.
05/31/1984 1984-05-003 Enhancements to the SEE-IN program recommended by NUTAC will be SCE to NRC LTR incorporated. Revisions to existing administrative programs or procedures or to 05/31/1984 training or other activities will ensure data reported to the SEE-IN program is complete and detailed enough to support the system enhancements being undertaken by INPO.
1984-05-002 Enhancements to the NPROS recommended by NUT AC will be incorporated.
SCE to NRC LTR Revisions to existing administrative programs or procedures and training will be 05/31/1984 accomplished to ensure a meaningful and effective implementa~ion of the NPROS program enhancements., Page 39 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1984-05-001 Review of existing internal programs and procedures, to ensure support of the SCE to NRC LTR NUTAC. will be complete prior to January 1, 1985.
05/31/1984 1984-04-014 Long-term corrective actions will be developed depending on the results of the SCE to NRC LTR preceding analysis. If potentially susceptible tubes are identified, a variety of 04/06/1988 corrective actions (e.g., preventive plugging/stabilization of potentially susceptible tubes, hardware and/or operational changes to reduce stability ratios, etc.) and/or long-term compensatory measures (e.g., enhanced leak rate monitoring programs) will be considered and to the extent practical will be implemented during the Cycle 10 refueling outage scheduled to start in July 1988.
1984-04-013 A stress ratio criteria will be developed based on the upper bound stress SCE to NRC LTR amplitude that could have been responsible for the failure of the tube which 04/06/1988 ruptured at North Anna. The AVB position information, the flow peaking factors, the results of the tube vibration analysis and the impact of past operation will be combined to determine which, if any San Onofre Unit 1 steam generator tubes exceed this stress ratio criteria.
1984-04-012 A dynamic analysis of the tubes in the regions of interest will be performed using SCE to NRC LTR the FLOVIB computer code based on the results of the thermal hydraulic analysis. 04/06/1988 The vibration analysis will determine tube stiffness, frequency and fluidelastic stability ratios for these tubes.
1984-04-011 Wind tunnel tests will be performed to determine the effects on fluidelastic SCE to NRC LTR instability of columnwise variations in AVB insertion depths. The criti velocities 04/06/1988 for fluidelastic instability will be obtained to determine the effects of AVB stagger on the instability. Peaking factors obtained will be expressed as a ratio of criti velocities among various AVB configurations, including the tube which ruptured at North Anna., Page 40 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1984-04-010 ATHOS, a three dimensional flow analysis code, will be used to calculate flow SCE to NRC LTR conditions in the regions of interest. A model will be set up with geometric 04/06/1988 parameters specific to San Onofre Unit 1. Detailed velocities, densities and void fractions for current operating conditions will be calculated.
1984-04-009 Eddy current testing (ECT) data has been obtained on all tubes in service in rows SCE to NRC LTR 11 through 17 in all three steam generators. (The nominal antivibration bar [AVB] 04/06/1988 position is row 14.) The ECT data will be analyzed to identify all of the tubes in this region of interest that are dented. The ECT data will also be evaluated to determine the number of AVB's in contact with each tube and the position of the contact points/arcs relative to the uppermost tube support plate. This AVB contact information will be used to determine the position of each AVB relative to the tubes it supports (the depth of penetration of each AVB). This effort will include consistency checks and independent verification of AVB position through geometric scaling techniques as required.
1984-04-008 Training on the basis for the San Onofre Unit 1 enhanced primary-to-secondary SCE to NRC LTR leak rate monitoring program will be conducted for all on-shift licensed reactor 04/06/1988 operators prior to return to full power operation from the current mid~cycle outage. In addition, Chemistry personnel will be trained on the methods utilized in the San Onofre Unit 1 enhanced monitoring program prior to return to full power from the current mid-cycle outage. Additional operator training on the North Anna Tube Rupture event is targeted for implementation the last half of 1988., Page 41 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1984-04-007 If the air ejector monitor is out-of-service, several methods will be utilized to SCE to NRC LTR ensure that primary-to-secondary leak rates continue to be monitored. These 04/06/1988 methods will include, but are not limited to, daily secondary coolant and air ejector off gas activity analyses, and review of trending data utilizing R-1216, Steam Generator Blowdown Monitor. The first gas samples collected will be evaluated within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of when the air ejector monitor is declared out-of-service. Thereafter, samples will be collected daily when leak rates are less than 40 gpd and shiftly when leak rates are greater than 40 gpd. The importance of monitoring primary-to-secondary leak rates while the air ejector monitor is out-of-service is recognized and it is intended to continue trending and review of other pertinent data to ensure any changes in leak rate are promptly evaluated.
1984-04-006 If the leak rate approaches 100 gpd, an evaluation of the need to reduce power. SCE to NRC LTR or commence shutdown will be performed. This evaluation will consider the leak 04/06/1988 rate data to date, the rate of change of the leak rate, and the leak rate measurement uncertainty. This evaluation will provide adequate time to reduce power or shutdown should a tube fatigue failure be in progress. Implementation of this program will be more conservative than would be required by the leak rate-time curve generated from the North Anna event.
1984-04-005 If evaluation shows that the primary-to-secondary leak rate is greater than 40 SCE to NRC LTR gpd or the leak rate has increased more than 15 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and continues to 04/06/1988 increase, the frequency of evaluation of the leak rate will be increased to at least once per shift. The evaluation will consider the possibility that a tube plug or sleeve may have caused the increased leak rate. Unlike the continuous increasing leak rate that occurred at North Anna, the leak rate from a defective plug or sleeve should stabilize and may even decrease. The alarm setpoint for th~ air ejector monitor will be increased to a value which corresponds to approximately a 15 gpd increase over the latest leak rate., Page 42 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1984-04-004 If an alarm is received from the air ejector monitor or calculations of primary-to-SCE to NRC L TR secondary leak rate show that the leak rate is increasing, confirmation of the 04/06/1988 change will be obtained by other methods. These will include, but are not limited to, reviewing the trends of the continuous blowdown monitor, or performance of radiochemistry analyses to allow independent calculations of the primary-to-secondary leak rate.
1984-04-003 During full power operation and with primary-to-secondary leak rates less than SCE to NRC LTR 15 gpd, the San Onofre Unit 1 leak rate monitoring program will consist ofthe 04/06/1988 following multi-faceted approach: 1) continuous monitoring utilizing R-1215 and R-1216, 2) radiochemistry analyses, 3) leak rate calculations, and 4) trending of data. The activity indications from the continuous monitors will be trended and reviewed once-a-day. The air ejector off gas flow rate will be logged and reviewed each day to assess changes in condenser air inleakage. Primary-to-secondary leak rates will be calculated daily as a function of the air ejector activity readings, air ejector flow rate, and the most recent primary coolant gaseous activity. The primary coolant total gaseous activity is normally measured three times per week for use in determining primary-to-secondary leak rate.
1984-04-002 The initial alarm setpoint for the air ejector monitor (R-1215) will be established SCE to NRC LTR prior to returning the unit to critiity. This alarm setpoint will correspond to the 04/06/1988 activity expected from a primary-to-secondary leak rate of 15 gallons per day (gpd).
1983-03-005 Additional information concerning our preventive maintenance program will be SCE to NRC LTR submitted separately. As discussed in Reference 2, neither Unit will enter Mode 2 03/30/1983 until advised by your office that the matter involving the reactor trip breakers is resolved.
1983-03-004 These deficiencies will be corrected by the preparation of a new procedure which SCE to NRC LTR incorporates the provisions of IE Bulletin 79-09, the vendor manual, and other 03/30/1983 inputs from the vendor. Maintenance in accordance with this new procedure will be performed on all Units 2 and 3reactor trip circuit breakers prior to their respective Model 2 entry., Page 43 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1983-03-002 Before San Onofre Unit 1 is permitted to leave Mode 5, the deficiencies of the SCE to NRC LTR Type DB circuit breaker maintenance procedure will be corrected, the 03/18/1983 maintenance required by Action Item No. 2 of IE Bulletin No. 83-01 will be performed, and the breaker surveillance testing specified by Action Item No. 1 of IE Bulletin No. 83-01 will'be repeated. The results of the breaker surveillance testing will be submitted to you within seven days oftest completion. Until the actions listed in this paragraph are completed, the two reactor scram breakers will not be declared operable.
1Q83-03-001 In summary, SCE is (1) committing to implement a forced lube oil cooling system SCE to NRC LTR to environmentally qualify the AFW pump motors, (2) committing to install the 03/07/1983 forced lube oil cooling system during the first refueling outage for each unit, (3) providing a detailed description of the forced lube oil system as described above and (4) committing to correct the error in the CPC software at the first refueling outage for each unit. The SONGS 2/3 FSAR will be amended to incorporate the forced lube oil cooling system in conjunction with the next regularly scheduled amendment.
1983-01-001 The Committees report will be submitte,d to the NRC at least two weeks prior to SCE to NRC LTR exceeding 5% power on Unit 3. SCE will submit proposed Technical Specifications 01/11/1983 for Unit 2 and revised Technical Specifications for Unit 3 upon completion of our review.
1982-07-001 Consistent with the above commitment, SCE is currently finalizing the scope of SCE to NRC LTR work for preparation of responses to the NRC questions and will transmit these 07/30/1982 responses to the NRC by June 30, 1983.
1982-01-001 Drafts of Combustion Engineering Owners Group generic procedure guidelines SCE to NRC LTR are presently scheduled for submittal to NRC for approval by approximately April 01/27/1982 1, 1982. Southern California Edison will incorporate the approved guidelines into SONGS-2 emergency procedures at the first refueling after January 1, 1983.
1981-10-002 As many operators as possible will participate in the actual performance of the SCE to NRC LTR planned cooldown presently scheduled for performance during the power 10/21/1981 ascension program as outlined in FSAR Section 14.2.12.105., Page 44 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1981-10-001 Station operating instruction S023-3-2.31 will be utilized to perform this SCE to NRC LTR evolution and contains several provisions and precautions to deal with the 10/21/1981 prevention or mitigation of reactor vessel voiding. Included are precautions delineating symptoms of inadequate core cooling, the minimum subcooled margin to be maintained and maximum cooldown rate to avoid head voiding.
Steps of the procedure, requiring operator verification, include continuous monitoring for void formation during depressurization as well as actions to be taken should evidence of void formation exist.
1981-09-001 SCE will incorporate appropriate administrative controls in the operating SCE to NRC L TR procedures for dning/fluid pumping of these tanks to preclude damage by 09/29/1981 vacuum conditions.
1981-08-001 The permanent corrective action will be to modify the control circuitry for MOV SCE to NRC LTR 1100 B, C, and D to incorporate a seal in/reset function on ESF actuation. This 08/06/1981 action is scheduled to be completed during the next refueling outage.
1981-07-001 Enclosed are sixty-three (63) copies of the response to the NRC interim, six SCE to NRC LTR month information request in the December 22, 1980 letter, concerning 07/07/1981 compliance with NUREG-0612, Control of Heavy Loads. As requested in your December 22, 1980 letter, SCE confirms that implementation of changes and modifications determined to be necessary will commence as soon as possible without waiting on NRC Staff review, so that all such changes, beyond the interim action, will be completed within two tears of submittal of the final, nine month response to the December 22,1980 information request.
1981-06-002 Testing to verify the adequacy of the systems under maximum noise conditions SCE to NRC LTR will be completed within 30 days of the unit return to sustained full load 06/15/1981 operation. Should the testing indicate that adjustments and/or repairs to systems components are necessary, corrective action will be taken to satisfy the bulletin requirements., Page 45 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1981-06-001 The physical modifications will be complete and the systems functionally SCE to NRC L TR servicable at the time the unit returns to service. In order to assure that the 06/15/1981 audibility of the equipment meets design specification, plant operation at or near full load is required to establish the maximum background noise levels prior to completing the systems tests.
1981-05-001 This information will be incorporated into the FSAR text, and direct distribution of SCE to NRC L TR this information will be made as part of the Amendment 25 distribution and will 05/07/1981 be in accordance with the service list provided by SCE's letter of October 29, 1979. An affidavit attesting to the fact that distribution has been completed will be provided within ten days of docketing of Amendment 21.
1981-02-001 All mechanical snubbers on safety-related systems will be inspected in SCE to NRC LTR accordance with IE Bulletin 81-01 prior to return to power from this outage.
02/27/1981 Within sixty (60) days of the completion of this mechani snubber inspection, a report of the results will be submitted to you.
1980-12-001 However, prior to returning to power from this outage, SCE will determine if any SCE to NRC LTR safety-related valves have parts cast by Malcolm Foundry Company, Inc. If it is 12/10/1980 determined that there are such parts: a) a visual inspection of those valve parts will be performed, b) a schedule for replacing potentially defective parts will provided, and c) the value manufacturer(s) will be identified., Page 46 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1980-05-006 We are presently reviewing existing procedures to determine any changes that SCE to NRC LTR may be appropriate to accomodate the effects identified in the FMEA. In 05/15/1980 addition, a new procedure will be developed for the loss of a 120V AC bus which will include the following: a) The diagnostics/alarms/indications/symptoms resulting from the loss of a 120v AC bus as developed in failure Modes and Effects Analysis. b) The use of alternative indication and/or control circuits which may be powered from other non-class 1-E instrumentation and control buses. c)
Methods for restoring power to the bus. d) Methods to be used in bringing the plant to a cold shutdown condition. This new procedure and changes to existing procedures will be implemented prior to return to power at the completion of the current refueling outage.
1980-05-005 Place the power supply to the solenoid valve of the following valves on separate SCE to NRC LTR buses: CV202, CV203, CV204. These three valves are the isolation valves on the 05/15/1980 three normal letdown orifices. m is would prevent complete isolation of normal letdown on loss of one bus. This change will be completed during the next maintenance outage of sufficient duration.
1980-05-004 Install indicator lights in the control room to alert the operator as to which bus is SCE to NRC LTR experiencing a loss of power. This will be completed prior to returning to power 05/15/1980 at the completion of the current refueling outage.
1980-05-003 As part of our responses to Items 1 and 2 above, we will provide proposed SCE to NRC LTR corrective actions, a schedule for completion of the corrective actions, and a 05/12/1980 description of any interim actions, it necessary.
1980-05-002 In conjunction with the scoping studies discussed above, a review oi the San SCE to NRC LTR Onofre Unit 1 main steam line break core response an*alysis is being conducted.
05/12/1980 The review will consider all of the aspects identified in Item 2 of your request.
The results of the review will be provided by May 16,1980., Page 4 7 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1980-05-001 The scoping studies will include the effect of auxiliary feedwater runout flow as SCE to NRC LTR well as the impact of other energy sources such as the addition of main 05/12/1980 feedwater or condensate flow due to the response of the feedwater control valves during the transient.
1980-03-003 As agreed in our telephone discussion of March 24, 1980, we will complete and SCE to NRC LTR forward our response to Bulletin 79-27 to your office by May 15, 1980. This 03/25/1980 response will include: 1. Completion of the failure mode and effects analysis required by Item lof the Bulletin. 2. A description of and new procedures or revisions of the old procedures and date of their implementation. 3. A description of the conceptual design modifications with schedule required by the results of the analysis.
1980-03-001 SCE will implement an inspection program in accordance with the requirements SCE to NRC L TR of NRC IE Bulletin No. 79-13, Revision 2 and your letter of November 14, 1979.
03/04/1980 1980-01-002 Those safety-related piping systems for which seismic analysis design documents SCE to NRC have not been retrieved will be evaluated as part of the Seismic Reevaluation Program at San Onofre Unit I, which has now been integrated into the Systematic Evaluation Program.
2013-06-002 Complete ERO training regarding multi-unit, multi-source dose assessment by SCE letter to NRC manually summing the individual dose assessment results for each unit.
6/28/2013 2013-06-001 Revise procedures to incorporate multi-unit, multi-source dose assessment by SCE letter to NRC manually summing the individual dose assessment results for each unit.
06/28/2013 2010-10-144 Track commitment in October 2010 supplemental submittal on 73.55 Exemption SCE letter to NRC to complete Room 112 CCTV work 10/17/2010 2010-08-009 Modify the ECP procedure S0123-XXIV-10.1, Att. 12), to provide the engineer SCE letter to NRC responsible for installing the design change with guidance as to when SPI owner 08/30/2010 must be notified of a field change.
2010-07-002 SCE will perform a supplemental site-wide Emergency Plan drill within 60 days of SCE letter to NRC issuance of this letter.
7/30/2010, Page 48 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 2009-12-007 As discussed in the public meeting, SCE commits to perform additional SCE letter to NRC confirmatory examinations of the divider plate welds following the installation of 12/07/2009 the RSGs for both Units 2 and 3. The examinations will consist of remote visual examinations ofthe accessible areas of the divider plate to channel head and tubesheet welds and repeat baseline straight beam ultrasonic examinations from the accessible locations outside the channel head. Examinations will be perfonned during the first steam generator inspection outage and in a steam generator inspection outage near the end of the first 10-year inspection interval for the RSGs for each unit."
2009-11-003 This supplemental response credit the replacement of Units 2 and 3 steam SCE letter to NRC generators. The Unit 3 replacement steam generators are scheduled to be 11/12/2009 installed during the fall 2010 cycle refueling outage.
2009-04-062 Modify the switchyard delay barrier at the south switchyard stairwell to increase SCE letter to NRC the creditable delay time. The switchyard stairwell razor wire on the north side of 01/13/2009 the switchyard has been installed.
2009-04-061
. Modify the switchyard delay barrier at the north switchyard stairwell to increase SCE letter to NRC the creditable delay time. The switchyard stairwell razor wire on the north side of 01/13/2009 the switchyard has been installed.
2008-10-005 An Engineering procedure will be developed to formalize SIT monitoring to SCE letter to NRC provide a formal process of quantifying leakage into the low pressure side of the 10/14/2008 Safety Injection system.
2008-10-003 Procedure S023-3-3.8, "Safety Injection Monthly Tests" (Reference 17) specifies SCE letter to NRC that one of the objectives is to vent accessible valves on the discharge side. The 10/14/2008 procedure vents valves on both the suction and discharge sides and vents valves deemed necessary to ensure that the system is sufficiently full without limitations imposed by accessibility. The procedure objective will be revised for clarification only.
2008-10-002 Procedure S023-3-2.7.2, "Safety Injection System Removal/Return to Service SCE letter to NRC Operation, (Reference 15) will be revised to include sweeping of the inverted "U" 10/14/2008 sections in the HPSI Train "A" discharge piping during plant restart until new vents are installed., Page 49 of 54
Commitment Number Verbatim Commitment to NRC
- Commit Source 2008-02-005 If the as-found TSP is outside the as-found predefined acceptance criteria band, SCE letter to NRC the condition shall be entered into t~e corrective action program for further 02/19/2008 evaluation 2008-02-004 If the as-found TSP is found to be conservative with respect to the AV, and SCE letter to NRC outside the as-found predefined acceptance criteria band, but SCE is able to 02/19/2008 determine that the relay is functioning as required and can be reset to within the setting tolerance of the limiting TSP, or a value more conservative than the limiting TSP, then the relay may be considered operable. If it cannot be determined that the relay is functioning as required, it shall be declared inoperable and the associated TS actions followed.
2008-02-003 If the as-found trip setpoint (TSP) is found to be nonconservative with respect to SCE letter to NRC the a"owable value (AV) specified in the TSs, the relay shall be declared 02/19/2008 inoperable and the associated TS action statement followed 2008-02-002 The relay setpoint shall be reset to a value that is within the as-left tolerance of SCE letter to NRC the nominal relay setpoint; otherwise, the relay shall be declared inoperable.
02/19/2008 2008-02-001 If the as-found relay setpoint is conservative with respect to the Allowable Value SCE letter to NRC but outside its predefined as-found acceptance criteria band, then the relay shall 02/19/2008 be evaluated to verify that it is functioning as required before returning the relay to service. If the as-found relay setpoint is not conservative with respect to the Allowable Value, the relay shall be declared inoperable 2007-11-010 Revise Operation procedure to provide ability to power a spare battery charger SCE letter to NRC from a diesel-backed source. This includes having all preparations in place prior 11/30/2007 to the 72-hour CT 2007-11-009 Include minimum established float voltage values for battery charger in the new SCE letter to NRC LCS Bases.
11/30/2007 200Z-11-008 Include appropriate battery maintenance practices from industry standard IEEE SCE letter to NRC 450-2002, and Reg Guide 1.129, Rev 2, positions 1, 2, 3, 6, and 8 in the new LCS 11/30/2007, Page 50 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 2007-11-007 Appropriate design features will be added to measure float charging current SCE letter to NRC when a swing battery charger is aligned to a Class lE subsystem battery 11/30/2007 2007-11-006 Maintain a capacity margin (presently 2%) to account for the uncertainty in the SCE letter to NRC battery capacity assigned by the manufacturer for allowed float current limit of 11/30/2007 1.50 amps for 1800 amp-hour batteries and.75 amp for 1260 amphour batteries 2007-11-005 Relocate battery parameters of cell voltage, electrolyte level, electrolyte SCE letter to NRC temperature, and float voltage from TS 3.8.6 to proposed Battery Monitoring and 11/30/2007 Maintenance Program.
2007-11-004 Relocate specific gravity monitoring to proposed Battery Monitoring and SCE letter to NRC Maintenance Program. This specific gravity monitoring will be performed prior to 11/30/2007 each battery discharge test 2007-11-003 Relocate the requirements of existing STs 3.8.4.2, 3,4,5 from the TSs to the LCS.
SCE letter to NRC Change frequency of existing SR 3.8.4.2 from 92 days to 31 days in LCS 11/30/2007 2007-11-002 Include minimum established float voltage of 129.0V in proposed TS Bases and SCE letter to NRC LCS.
11/30/2007 2007-11-001 SCE commits to measuring "As-Found" and "As-Left" data for the relay Dropout SCE letter to NRC and Pickup values within six month*s of operation at the new setpoints 11/5/2007 2007-06-001 SCE commits to implement a new calibration protocol for the PICs prior to SCE letter to NRC implementation ofthe approved emergency plan change 06/18/2007, Page 51 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 2006-08-002 The Shift Manager/Emergency Coordinator will be responsible for assigning a SCE letter to NRC non-shift Units 2/3 licensed operator to notify the NRC following notification of 08/28/2006 offsite agencies and within one hour of the event declaration. This individual will serve as the Control Room Emergency Notification System (ENS) Communicator to provide additional information as necessary or maintain communication with the NRC if requested until the TSC Red Phone Communicator arrives in the TSC and assumes that responsibility. The Control Room ENS Communicator will fulfill the responsibility of the 30- minute responder as designated in NUREG0654, Table 8-1 for communications and shown in Attachment 2.
2005-04-001 Training of procedures S023-13-25 and S0123-Xlll-4.10.2, Rev 8 to be completed SCE letter to NRC within 30 days 04/28/2005 2004*12-007 Following approval of this license amendment request, future revisions to SCE letter to NRC Accident Monitoring setpoint calculations will reflect the AST source term 12/27/2004 2004-12-006 Raddose V dose assessment software will be evaluated by June 30, 2005, to SCE letter to NRC determine what specific changes may be warranted in order to maintain 12/27/2004 consistency with the manual dose assessment calculation methodology r
2004-12-005 Following approval of this license amendment request, the manual dose SCE letter to NRC calculation methodology as described in Emergency Planning Implementation 12/27/2004 Procedures (EPIPs) and other Emergency Planning guidance documents will be revised to reflect AST methodology 2004-12-004 Following approval of this license amendment request (PCN 555), future revisions SCE letter to NRC to UFSAR Chapter 15 design basis accident control room and offsite radiological 12/27/2004 consequence analyses will be performed using AST methodology, Page 52 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1998-12-013 Comply with Risk-Informed lnservice Testing (RI-IST} program submitted in letter SCE letter to NRC dated 12/30/98 includes 457 pages total. Section 3.5 states: "As a living process, 12/30/1998 components will be reassessed at a frequency not to exceed every other refueling outage (initiated based on Unit 3 refueling outages) to reflect changes in plant configuration, component performance test results, industry experience, and other inputs to the process. The RI-IST reassessment will be completed within 9 months of completion of the outage."
1989-04-011 Modify Station procedures to require that during a station blackout event, load SCE letter to NRC group A is connected to battery C and load group B is connected to Battery D 04/17/1989 with the installed cable after approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> into the SBO event (exact cross connect time window to be determined by analysis later).
1989-04-010 Install cable and conduit between DC Buses A and C and DC Buses 8 and D (but do SCE letter to NRC not connect);
04/17/1989 1989-04-009 Minor procedure changes will be implemented in the SBO response procedure to SCE letter to NRC ensure all of the Provisions of NU MARC 87-00, Section 7 are included 04/17/1989 1989-04-008 San Onofre Unit 2 and 3 currently have an SBO response procedure, 5023-13.1, SCE letter to NRC "Station Blackout". This procedure will be reviewed and modified as necessary to 04/17/1989 satisfy the requirements of NU MARC 87-00, Section 4.2.1 1989-04-007 SCE will develop a severe weather response procedure in accordance with SCE letter to NRC NU MARC 87-00, Section 4.2.3 04/17/1989 1989-04-006 In the event that San Onofre Unit 2 and 3 becomes blacked out, actions SCE letter to NRC necessary to restore power to the switchyard would be fulfilled by Unit 2/3 04/17/1989 operators. This procedure will be reviewed. and modified as necessary to meet NU MARC 87-00, Section 4.2.2, Page 53 of 54
Commitment Number Verbatim Commitment to NRC Commit Source 1989-01-002 Prior to entering an RCS Reduced Inventory Condition, each operating shift and SCE letter to NRC Equipment Control personnel will receive training, which covers plant operation 01/05/1989 while in such a condition. The purpose of this training will be to increase awareness of the complexities involved while operating with the reactor Coolant System at Mid loop. The training will include a discussion of related industry events (including the April 10, 1987 Diablo Canyon loss of residual heat removal (RHR) event), Containment closure control, methods of adding inventory to the RCS, establishing a Hot Leg vent path, indications for monitoring RCS level and temperature, and the necessity of maintaining control over those types of activities which could perturb stability of the RCS. This training will be accomplished within 30 days prior to entering a Reduced Inventory Condition and may be waived if completed within the previous six months. The training material will be periodically updated as the need occurs 1988-12-001 To comply with guideline (iii) of Generic Letter 81-12, SCE will implement the SCE letter to NRC following test program for circuit breakers which support Appendix R breaker 12/01/1988 coordination:... All Appendix R credited molded case circuit breakers shall be demonstrated operable once per refueling interval by selecting and functionally testing a sample of at least 10% of the Appendix R credited molded case circuit breakers. Circuit breakers selected for functional testing shall be selected on a rotating basis such that, within 10 refueling intervals, the entire population is tested. Testing of these circuit breakers shall demonstrate that Appendix R credited breaker coordination is maintained. For each circuit breaker found inoperable during these functional tests, an aditional sample of 10% of all of the circuit breakers of the inoperable type shall also be functionally tested until no more failures are found or all circuit breakers of that type have been functionally tested., Page 54 of 54
ENCLOSURE 3 LIST OF COMMITMENTS APPLICABLE TO SAN ONOFRE NUCLEAR GENERATING STATION AS OF APRIL 1, 2019
Commitment Number Status 2015-02-001 Fulfilled 2014-09-001 Fulfilled 2014-01-001 Working 2013-06-002 Fulfilled 2013=06-001 Fulfilled 2010-08-009 Fulfilled 2007-09-001 Fulfilled 2007-07-001 Fulfilled Verbatim Commitment to NRC SCE will ensure licensee-controlled documents are. in place to require the continuing performance of 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. Revised commitment: every five years.
Procedures will be revised to ensure tha_t walk-downs and patrols [of SFP systems] are periodically (no less than once a shift) performed.
Report on changes to Mitigating Strategies. Update Commitment Change Report dated 1/2/14. letter contains Security Related Information, contents of the enclosure were withheld.
Complete ERO training regarding multi-unit, multi-source dose assessment by manually summing the individual dose assessment results for each unit Revise procedures to incorporate multi-unit, multi-source dose assessment by manually summing the individual dose assessment results for each unit.
Modify the ECP procedure S0123-XXIV-10.1, Att. 12), to provide the engineer responsible for installing the design change with guidance as to when SPI owner must be notified of a field change.
l)For all heavy load lifts, ensure 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.
SCE will apply a 6.6% reduction to the CECOR computer code determination of fuel assembly burnup for all fuel assemblies prior to determination of the allowable storage location per the proposed TS 4.3.1 and LCS 4.0.100., Page 1 Commit Source SCE to NRC LTR 2/23/2015 SCE to NRC LTR 9/9/2014 SCE to NRC LTR 1/2/14 SCE to NRC LTR 6/28/13 SCE to NRC LTR 6.28/13 SCE to NRC LTR 8/30/10 NEI 08-05 SCE to NRC LTR RAI 07/27/2007
Commitment Number Status Verbatim Commitment to NRC 2007-01-007 Fulfilled SCE will conduct training on the mitigation strategy procedures/guidelines.
Training on the procedures will be commensurate with the level of training provided for Severe Accident Management Guidelines (SAM Gs).
2007-01-006 Fulfilled SCE will list the viable site specific reactor/ containment strategies in appropriate procedures 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 as site-specific SFP mitigation strategies in appropriate plant procedures that could be used by emergency response organization or plant personnel.
2007-01-005 Fulfilled SCE will implement the PWR mitigation strategies in plant procedures as described in Tables A.4-1 through A.4-7 of Enclosure 1. [The enhanced strategy given in Table A.4-4 will be implemented following the next refueling outages.]
2007-01-004 Fulfilled SCE will include the command and control enhancement strategies in plant procedures as described in Table A.3-1 of Enclosure 1.
2007-01-003 Fulfilled SCE will include the SFP external makeup strategy and SFP external spray strategy in plant procedures as described in Tables A.2-1 through A.2-6 of Enclosure (1).
2006-05-006 Fulfilled Make informal notification as soon as practicable to appropriate State/Local 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 any water sample result for onsite groundwater that is or may be used as a source of drinking water that exceeds the criteria in the licensees 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;, Page 2 Commit Source SCE to NRC LTR 01/10/2007 SCE to NRC LTR 01/10/2007 SCE to NRC LTR 01/10/2007 SCE to NRC LTR 01/10/2007 SCE to NRC LTR 01/10/2007 SCE to NRC LTR 8/1/2006 NEI 07-07 SCE to NRC LTR 8/1/2006 NEI 07-07
Commitment Number Status Verbatim Commitmenfto NRC 2006-05-004 Fulfilled Document all onsite groundwater sample results and a description of any 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 action plan(s) to help assure timely detection and effective response to situations involving inadvertent radiological re.leases in groundwater to prevent migration of licensed radioactive material offsite and quantify impacts on decommissioning.
2004-12-004 Fulfilled Following approval of this license amendment request (PCN 555), future revisions to UFSAR Chapter 15 design basis accident control room and offsite radiological consequence analyses will be performed using AST methodology.
2004-12-003 Fulfilled SCE is making a regulatory commitment to provide information to the NRC annually to support the apportionment of station dose for SONGS Ul, U2 & U3 and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).
1998-12-001 Fulfilled SCE will decontaminate and dismantle the facilities and structures that will 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 consistent with NEI 96-07, Revision 1, These requirements are incoprorated in S0123-XV-44 Rev 19.
1991-09-001 Fulfilled We are currently completing the procedures to implement the vendor interface program. These procedures will be completed by October 31, 1991.
1990-03-006 Fulfilled The consolidated NRC open item and commitment tracking program will be implemented by June 1, 1990. Review of NRC commitments and tracking program documentation will be completed by August 1, 1990.
1990-03-003 Fulfilled SCE will develop a severe weather response procedure in accordance with NU MARC 87-00., Page 3 Commit Source SCE to NRC LTR 8/1/2006 NEI 07-07 SCE to NRC LTR 8/1/2006 NEI 07-07 SCE to NRC LTR 12/27/2004 SCE to NRC LTR 12/27/2004 SCE to NRC LTR 12/15/1998 SCE to NRC LTR 11/17/1997 SCE to NRC LTR 09/30/1991 SCE to NRC LTR 03/19/1990 SCE to NRC LTR 03/12/1990
Commitment Number Status Verbatim Commitment to NRC 1981-07-001 Fulfilled Enclosed are copies of the response to the NRC interim, six month information request in the December 22, 1980 letter, concerning compliance with NUREG-0612, Control of Heavy Loads. As requested in your December 22, 1980 letter, SCE confirms that implementation of changes and modifications determined to be necessary will commence as soon as possible without waiting on NRC Staff review, so that all such changes, beyond the interim action, will be completed within two years of submittal of the final, nine month response to the December 22,1980 information request., Page 4 Commit Source SCE to NRC LTR 07/07/1981
ENCLOSURE 4 SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3 REVISED TECHNICAL SPECIFICTION BASES PAGES FOR THE PERIOD FROM APRIL 1, 2017 THROUGH APRIL 1, 2019
Fuel Storage Pool Water Level B 3.1.1 B 3.1 PLANT SYSTEMS B 3.1.1 Fuel Storage Pool Water Level BASES BACKGROUND APPLICABLE SAFETY ANALYSES LCO APPLICABILITY San Onofre - Draft The minimum water level in the fuel storage pool meets the assumptions of iodine decontamination factors following a fuel handling accident. The specified water level shields and minimizes the general area dose when the storage racks are filled to their maximum capacity. The water also provides shielding during the movement of spent fuel.
A general description of the fuel storage pool design is given in the UFSAR, Section 9.1.2, Reference 1, and the Independent Spent Fuel Pool Cooling System is given in the UFSAR, Section 9.1.3 (Ref. 2). The assumptions of the fuel handling accident are given in the UFSAR, Section 15.1.1.4 (Ref. 3).
The minimum water level in the fuel storage pool meets the assumptions of the fuel handling accident described in Regulatory Guide 1.183 (Ref. 4 ). The resultant dose to a person at the exclusion area boundary or low population zone is a small fraction of the 10 CFR 50.67 (Ref. 5) limits.
According to Reference 4, there is 23 ft of water between the top of the damaged fuel bundle and the fuel pool surface for a fuel handling accident. With a 23 ft water level, the assumptions of Reference 4 can be used directly. In practice, this LCO preserves this assumption for the bulk of the fuel in the storage racks. In the case of a single bundle,. dropped and lying horizontally on top of the spent fuel racks, however, there would be < 23 ft of water above the top of the bundle.
The fuel storage pool water level satisfies Criterion 3 of the NRC Policy Statement.
The specified water level preserves the assumptions of the fuel handling accident analysis (Ref. 3). As such, it is the minimum required for fuel storage and movement within the fuel storage pool.
This LCO applies during movement of fuel assemblies (i.e., irradiated fuel, non-irradiated fuel, and the dummy fuel assembly) in the fuel storage pool since the potential for a release of fission products exists.
83.1.1-1 Revision 1
BASES ( continued)
ACTIONS SURVEILLANCE REQUIREMENTS REFERENCES San Onofre - Draft Fuel Storage Pool Water Level B 3.1.1 When the initial conditions for an accident cannot be met, steps should be taken to preclude the accident from occurring. When the fuel storage pool water level is lower than the required level, the movement of fuel assemblies in the fuel storage pool is immediately suspended. This effectively precludes a spent fuel handling accident from occurring. This does not preclude moving a fuel assembly to a safe position.
SR 3.1.1.1 This SR verifies sufficient fuel storage pool water is available in the event of a fuel handling accident. The water level in the fuel storage pool must be checked periodically. The 7 day Frequency is appropriate because the volume in the pool is normally stable. Water level changes are controlled by unit procedures and are acceptable, based on operating experience.
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UFSAR, Section 9.1.2.
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UFSAR, Section 9.1.3.
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UFSAR, Section 15.1.1.4.
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B 3.1.1-2 Revision 1