ML13310B289

Forwards Request for Addl Info Re Proposed Changes 76 & 126 to Tech Specs.Info Requested within 30 Days of Ltr Date

ML13310B289
Person / Time
Site:	San Onofre
Issue date:	03/09/1984
From:	Crutchfield D Office of Nuclear Reactor Regulation
To:	Baskin K Southern California Edison Co
References
TAC-10853 LSO5-84-03-012, LSO5-84-3-12, NUDOCS 8403130216
Download: ML13310B289 (5)

Text

March 9, 1984 DISTRIBUTION Docket File NRC PDR Local PDR Docket No. 50-206 NSIC LS05-84-03-012 ORB #5 Reading DCrutchfield HSmith EMcKenna OELD Mr. Kenneth P. Baskin ELdordan Vice President, Nuclear Engineering JNGrace Licensing and Safety Department ACRS (10)

Southern California Edison Company GZwetzig, Region V 2244 Walnut Grove Avenue Post Office Box 800 Rosemead, California 91770

SUBJECT:

PROPOSED CHANGES NOS. 76 AND 126 TO THE TECHNICAL SPECIFICATIONS Re:

San Onofre Nuclear Generating Station, Unit No. 1 By letters dated October 20, 1978 and November 30, 1983, you forwarded Proposed Changes Nos. 76 and 126, respectively, to the San Onofre Unit No. 1 Technical Specifications. In reviewing your submittals, we find we need the additional information listed in the enclosure.

It is requested that this information be submitted to the office, with a copy to Mr. G. Zwetzig of the NRC Region V Office within 30 days of the date of thisPletter.

This request for information was approved by 0MB under clearance number 3150-0065. Comments on burden and duplication may be directed to the Office of Management and Budget, Reports and Management, Room 3208, New Executive Office Building, Washington, D.C.

Sincerely, original signed by Dennis M. Crutchfield, Chief Operating Reactors Branch #5 Division of Licensing

Enclosure:

Request for Additional Information cc w/enclosure:

See next page DL P"K &5 DL EMcKenna ~c Drt chfield 8403130216 840309 PDR ADOCK 05000206.

D. Bs

Mr. Kenneth P. Baskin 2 -

March 9, 1984 cc Charles R. Kocher, Assistant General Counsel James Beoletto, Esquire Southern California Edison Company Post Office Box 800 Rosemead, California 91770 David R. Pigott Orrick, Herrington & Sutcliffe 600 Montoqmery Street San Francisco, California 94111 Harry B. Stoehr San Diego Gas & Electric Company P. 0. Box 1831 San Diego, California 92112 Resident Inspector/San Onofre NPS c/o U.S. NRC P. 0. Box 4329 San Clemente, California 92672 Mayor City of San Clemente San Clemente, California 92672 Chairman Board of Supervisors County of San Diego San Diego, California 92101 California Department of Health ATTN: Joseph 0. Ward, Chief Radiation Control Unit Radiological Health Section 714 P Street, Room 498 Sacramento, California.95814 U.S. Environmental Protection Agency Region IX Office ATTN:

Regional Radiation Representative 215 Freemont Street San Francisco, California 94111 John B. Martin, Regional Administrator Nuclear Regulatory Commission, Region V 1450 Maria Lane Walnut Creek, California 94596

Enclosure Request for Additional Information San Onofre Nuclear Generating Station, Unit 1 Docket No. 50-206

1.

Please provide a copy of the proposed revised Technical Specifications which retains the provisions relating to the Auxiliary Feedwater System, includes bold lines in the right hand margin identifying the requested revisions, and incorporates any additional revisions you find appropriate as a result of your review of this request for additional information.

2.

Please provide lists or legible drawings showing the loads served by Vital Buses 1, 2, 3, 3A, 4, 5 and 6.

3..

Regarding proposed Specification 3.7.11:

a.

Please explain why the Safety Injection System Load Sequencers and the UPS are not required to be operable in Mode 4 when all other systems needed for Safety Injection are required to be operable in Mode 4, the Standard Technical Specifications (STS) require safety injection capability in Mode 4, and San Onofre-1 Specification 3.5.5 requires the Sequencer subchannels to be operable in Mode 4.

Alternatively, revise your request to include an operability requirement in Mode 4.

b.

Please provide justification for allowing the automatic loading function (as opposed to an RCS low pressure SI signal) to be blocked in Mode 3 when RCS pressure is less than 1900 psig. Your proposal suggests that Safety Injection or Containment Spray would not be needed when the RCS pressure is below 1900 psig; however, it is not clear this is the case.

c.

Please provide justification for the proposed time limits for correcting inoperable conditions as stated in Specification 3.7.II.B.1, or revise the time limits to be consistent with Specifications 3.7.I.B.7 and 8.

4.

Regarding proposed Specification 3.7.III.A.4:

a.

Please revise the wording to clarify whether'this provision revises all of the preceding paragraphs (III.A.1, 2 and 3) or only III.A.3.C, or some other interpretation.

b.

We note your discussion of Vital Buses needed during Modes 5 and/or 6 does not mention Containment Pressure Instrumentation (TS 3.6.1.C), Fire Protection Systems (TS 3.14) or the Residual Heat Removal or Spent Fuel Cooling functions -

all of which are needed in these modes. Please confirm the adequacy of your proposed listing of required Vital Buses with respect to these other functions required during Modes 5 and 6.

5.

We note the battery surveillance acceptance criteria specified in proposed Table 4.4-1 are numerically the same as those listed in the

2 Westinghouse Standard Tech Specs (STS) (Spec. 4.8.2).

We also note the STS numerical values assume a manufacturer's recommended-full charge specific gravity of 1.215.

Please confirm that the manufacturer's recommended full charge specific gravity for the batteries subjectato this proposed specification is 1.215, or provide revised values appropriate to the manufacturer's recommended value and a description of the method and references used in developing the revised values.

6.

Regarding the results of the battery tests transmitted by your letter of August 26, 1983:

a.

We note the test results for the MOV-850C Uninterruptible Power Supply (UPS) yielded a capacity of 84%. You state in your letter of transmittal that this value should be interpreted in light of the fact that the UPS did not receive an equalizing charge which is normally applied three to seven days prior to the test. Our review of IEEE Std. 450-1980 (IEEE-450) indicates this is an improper interpretation and that equalizing charges (and checks of battery connections) should not be performed prior to the conduct of performance tests -

Secs. 5.2.(1) and 6.1, IEEE-450.

Accordingly, the fact that an equalizing charge was not applied means this aspect of the test conformed to the requirements of the standard. It also appears that the UPS will require an annual performance test in order to conform to IEEE-450, Sec. 5.2(3).

Please indicate whether the performance test of the UPS conformed to all requirements of IEEE-450 pertaining to such tests, and describe your.plans for future testing or replacement of the UPS battery.

b.

Please indicate whether the tests of the batteries for D. C. Buses Nos. 1 and 2 were preceded by the actions specified in Secs. 6.1(1) and 6.1(2) of IEEE-450. If so, please provide justification for the validity of the tests or your plans for re-performance of the tests.

In addition, please indicate if these performance tests were preceded by the service tests required by facility Technical Specification 4.4.D.e.

7.

We note you have not proposed a minimum average electrolyte temperature for the UPS. Your submittal states this is acceptable because the UPS is not needed in Mode 4 and because calculations indicate the UPS has adequate capacity to perform its safety function at electrolyte temperatures as low as 350F. We find this explanation questionable on three counts:

a.

As noted in Question 3.a, it is not clear that the UPS is not needed in Mode 4. Your response to Question 3.A may resolve this concern.

b.

We find calculations to be subject to errors and generally inferior to actual tests.

Since test data for the UPS should be available, these data could indicate acceptable electrolyte temperatures.

c.

Regardless of the requirement for the UPS during Mode 4, we believe

3 some minimum electrolyte temperature requirement should be proposed such that there is reasonable assurance that the UPS can perform its safety function when needed. Existing test data from successful tests could provide a sound basis for such a temperature requirement.

Accordingly, please revise your submittal to provide a minimum electrolyte temperature for the UPS and provide the technical basis for the proposed value as developed from test data.

8.

Please provide or reference an analysis showing the loads which require power from D.C. Buses 1 and 2, and the capability of those buses to supply these loads for at least ninety minutes. Also provide the results of tests, if any, which confirm this analysis.