ML13303B038
| ML13303B038 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 12/28/1988 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML13303B034 | List: |
| References | |
| NUDOCS 8901050161 | |
| Download: ML13303B038 (3) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO PCN-223, PCN-225, AND PCN-245 SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS AND ELECTRIC COMPANY THE CITY OF RIVERSIDE, CALIFORNIA THE CITY OF ANAHEIM, CALIFORNIA SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 DOCKET NOS. 50-361 AND 50-362
1.0 INTRODUCTION
Southern California Edison Company (SCE), on behalf of itself and San Diego Gas and Electric Company, The City of Riverside, California, and The City of Anaheim, California (the licensees), has submitted applications for license amendments for the San Onofre Nuclear Generating Station (SONGS),
Units 2 and 3, located in San Diego County, California. The NRC staff's evaluation of these applications, designated as PCN-223, PCN-225, and PCN-245, is described below.
2.0 EVALUATION PCN-223 By letter dated May 12, 1987 SCE submitted proposed change NPF-10/15-223.
This change would revise Table 3.3-12 of Technical Specification 3.3.3.8, "Radioactive Liquid Effluent Monitoring Instrumentation," to modify the action requirements when the minimum number of operable channels is less than required for certain effluent line monitoring instrumentation. For the Steam Generator Blowdown Effluent Line and the Steam Generator Blow down Bypass Effluent Lines, the change would replace the current require ment (when specific activity of the secondary coolant is greater than 0.01 microcuries/gram dose equivalent 1-131) to analyze samples at least once per eight hours, with a requirement to collect samples at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and analyze them within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of collection; it would also replace the requirement (when specific activity of the secondary coolant is less than 0.01 microcuries/gram dose equivalent 1-131) to analyze samples at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, with a requirement to collect samples at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and analyze them within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of
- 90105016,1 8812281 PDR ADOCK 05000361 P
_PDC
-2 collection. For the Turbine Building Sumps Effluent Line, this change would replace the current requirement to collect and analyze samples at least once per eight hours with the same requirements proposed above for the Steam Generator Blowdown Effluent and the Steam Generator Blowdown Bypass Effluent Lines.
Because the Standard Technical Specifications (STS) state that samples shall be collected and analyzed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the specific activity of the secondary coolant is greater than 0.01 microcuries/gram dose equivalent 1-131, the staff requested SCE to provide a plant specific justification for this deviation from the STS.
By letter dated March 3, 1988 SCE responded to this request and stated that the proposed change is consistent with the intent of the STS. The staff does not agree. As SCE pointed out in its March 3 submittal, "once the equilibrium pattern is developed,....each grab sample will be collected within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and analyzed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of its collection with respect to...the onset of a 0.01 microcuries/gram dose equivalent 1-131 specific activity. This is the position addressed in PCN-223."
Such a position is clearly at variance with the STS which calls for collection and analysis within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
Because the proposed time for analysis of the samples would not provide prompt identification of a problem, this change is not acceptable.
PCN-225 By letter dated May 12, 1987 SCE submitted proposed change NPF-10/15-225.
This change would redefine the Surveillance Requirements on operability in Technical Specification 4.11.1.3, "Liquid Waste Treatment," and in Technical Specification 4.11.2.4, "Gaseous Radwaste Treatment." It would also modify note d of Table 4.11-2 to Technical Specification 4.11.2.1.
This note currently requires that the continuous sampler charcoal and particulate samples be changed at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for at least 7 days following each shutdown, startup, or thermal power change exceeding 15 percent of rated thermal power in one hour and that the analyses be completed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of changing. The proposed note would require those samples to be changed at least once between 28 to 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> following each shutdown, startup, or thermal power change exceeding 15 percent of rated thermal power in one hour and that the analyses be completed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of changing.
SCE, in its justification for this change, stated that radioiodines and principal gamma emitters tend to peak out within the first 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and that any sample taken between 28 and 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> would provide a better indication of the peak concentration of those radioactive materials than would sampling every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for 7 days. The staff requested data and analysis to substantiate the claim that radioiodines and the principal gamma emitters tend to peak in the first 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. By letter dated March 3, 1988 SCE responded to this request. The staff reviewed the data provided by SCE and found that the peaks did occur within the first 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, however, they varied from 2 to 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br /> following the transient.
It also appeared that there was no way to correlate a single sample to a peak value. For example, from SCE's data on two transients whose peaks differed by 39%, the staff found that approximately 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> after the events, the one with the higher peak exhibited a total activity about 15%
lower than the other. In another example of two transients whose peaks differed by 68%, the event with the larger peak exhibited a total activity 39% greater than the other 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> after the events. Both of these examples used transients whose peaks and subsequent samples occurred within one half hour of each other. Because the transient activity cannot be accurately determined from a single sample, this proposal is not acceptable.
PCN-245 By letter dated September 1, 1987 SCE submitted proposed change NPF-10/
15-245. This change would remove the iodine/particulate channels of the Fuel Handling Isolation System (FHIS) from Technical Specification 3/4.3.2, "Engineered Safety Feature Actuation System Instrumentation," and from Technical Specification 3/4.3.3.1, "Radiation Monitoring Instrumentation."
This would allow the iodine/particulate channels to be removed or abandoned in place.
SCE based this request on Section 11.5 of the Standard Review Plan (SRP) which calls for monitoring and automatic control feature initiation of the fuel storage area ventilation system to be performed by noble gas instruments. However, the SRP also calls for continuous sampling for iodine and particulates in the fuel storage area ventilation effluent.
Therefore, while the iodine/particulate channels are not required for automatic control, they are necessary for continuous monitoring of the effluent. For this reason, the request to remove the iodine/particulate channels is not acceptable.
Principal Contributor: D. Hickman