ML13316B504
| ML13316B504 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/26/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML13316B501 | List: |
| References | |
| NUDOCS 9011070248 | |
| Download: ML13316B504 (4) | |
Text
- g Rg UNITED STATES 0
NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.135TO PROVISIONAL OPERATING LICENSE NO. DPR-13 SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS AND ELECTRIC COMPANY SAN ONOFRE NUCLEAR GENERATING STATION, UNIT NO. 1 DOCKET NO. 50-206
1.0 INTRODUCTION
By Proposed Change No. 187, which was submitted by Amendment Application No. 178, dated June 11, 1990, Southern California Edison Company (the licensee) requested an amendment to the Technical Specifications (TS) for San Onofre Nuclear Generating Station, Unit No. 1. The proposed change would revise TS 4.0.3 and TS 4.0.4, and would revise the basis sections for TS 3.0 and 4.0.
These changes are in accordance with Generic Letter (GL) 87-09, "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements." The proposed change would add a provision in TS 4.0.3 allowing a delay of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to permit completion of surveillance activities when.the allowable outage time limits are either not specified by the applicable action requirement or are less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. It would also revise TS 4.0.4 to include a provision to allow passage through or to operational modes to comply with action requirements.
The proposed revision to the basis for all specifications in sections 3.0 and 4.0 would provide better justification and clarify the intent of these specifi cations.
The licensee stated in its submittal that the guidance of GL 87-09 was being implemented with two exceptions. First, the changes applicable to TS 3.0.4 and parts of the basis for TS 3.0.4 were not being revised as a result of previous discussions with the NRC staff. Second, the changes applicable to the basis for TS 4.0.5 of the STS regarding inservice inspection and testing (IST) requirements were not being incorporated.
The licensee supplemented its amendment request by letter dated October 12, 1990, to correct an error that existed in the proposed basis for TS 3.0.4.
Because the licensee was not requesting the changes to TS 3.0.4 that were suggested by GL 87-09, the second sentence of the proposed basis for TS 3.0.4 was not applicable and should not have been included. The supplementary information corrected this error.
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-2 2.0 EVALUATION Specification 4.0.3 In Generic Letter 87-09, the staff stated that it is overly conservative to assume that systems or components are inoperable when a surveillance requirement has not been performed, because the vast majority of surveillances demonstrate that systems or components are operable. Since the allowable outage time limits of some action requirements do not provide an appropriate time limit for performing a missed surveillance before shutdown requirements apply,.the Technical Specifications should include a time limit that would allow a delay of the required actions to permit the performance of missed surveillances.
This time limit should be established giving due consideration for plant conditions, adequate planning, availability of personnel, the time required to perform the surveillance, as well as, the safety significance of the delay in completing the surveillance.
Based on the considerations discussed above, the staff concluded that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would be an acceptable time limit for completing a missed surveillance when the allowable outage times of the action requirements are less than this time limit or when shutdown action requirements apply. The 24-hour time limit would balance the risks associated with an allowance for completing the surveillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems (when the alternative is a shutdown to.
comply with action requirements before the surveillance can be completed).
This limit does not waive compliance with TS 4.0.3. Under TS 4.0.3, the failure to perform a surveillance requirement will continue to constitute noncompliance with the operability requirements of a limiting condition for operation. It will also cause the applicable action requirements to be invoked.
Therefore, based on the above discussion, the staff concurs that the change to TS 4.0.3 is acceptable.
Specification 4.0.4 TS 4.0.4 prohibits entry into a mode or other specified condition until all required surveillances have been performed. This could cause an interpretation problem when mode changes are required in order to comply with action statements.
Specifically, two possible conflicts between TS 4.0.3 and 4.0.4 could exist.
The first conflict arises because TS 4.0.4 prohibits entry into an operational mode or other specified condition when surveillance requirements have not been performed within the specified surveillance interval. The second potential conflict arises because an exception to the requirements of TS 4.0.4 is allowed when surveillance requirements can only be completed after a mode change is made. However, after the mode change has been made, the requirements of TS 4.0.3 are violated if the surveillance requirements for that mode were not performed within the specified surveillance interval.
-3 The licensee proposes to resolve these.conflicts by revising TS 4.0.4 as suggested by GL 87-09. The staff provided a clarification in GL 87-09 that:
(a it is not the intent of TS 4.0.3 that the action requirements preclude the performance of surveillance allowed by authorized exceptions to TS 4.0.4; and (b) the 24-hour delay allowed by TS 4.0.3 provides an appropriate time limit for completing surveillance requirements that become applicable as a consequence of TS 4.0.4 exceptions.
Therefore, based on the above discussion, the staff concurs that the change to TS 4.0.4 is acceptable.
Section 3.0 and 4.0 Bases The staff reviewed the proposed changes to the bases for TS sections 3.0 and 4.0. The staff finds that the proposed revision to the bases section for all specifications in TS 3.0 and 4.0 would provide better justification and clarify the intent of the specifications.. However, because the licensee did not request the revision to TS 3.0.4 which was suggested by the generic letter, the second sentence of the proposed basis for TS 3.0.4 was not applicable and was deleted. The licensee agreed to this modification of the TS 3.0.4 basis during discussions with the staff and supplemented its amendment application accordingly by letter dated October 12, 1990. Therefore, with this modification, the staff concurs that the proposed changes to the bases for TS sections 3.0 and 4.0 are acceptable.
Exceptions The licensee has chosen not to request the changes to TS 3.0.4 and to the basis for STS 4.0.5 that were suggested by GL 87-09. In the.case of TS 3.0.4, after the generic letter was issued, the staff determined that plant specific review and certification regarding the use of TS 3.0.4 would be required by each licensee requesting this change. The licensee has not completed this review and certification process and therefore, is not requesting the change to TS 3.0.4 that was suggested by GL. 87-09. In the case of the basis for STS 4.0.5, the generic letter suggested certain clarifications regarding IST requirements. IST requirements for San Onofre Unit 1 are currently specified by Section 4.7 of the unit's Technical Specifications., not Section 4.0.5 as in the STS. The licensee did not feel that.a clarification to the basis for TS 4.7 was necessary and, therefore, did not request the change.
Generic Letter 87-09 was issued to identify changes that could be made to improve Technical Specifications which would be acceptable to the NRC staff.
Licensees are not required to request Technical Specification changes that have been suggested by the generic letter, however; and it is acceptable for licensees to request some changes and not others. Therefore, the exceptions taken by the licensee to GL 87-09 are acceptable.
3.0 CONTACT WITH STATE OFFICIAL The staff has advised-the State Department of Health Services, State of California, of the proposed determination of no significant hazards consideration.
No comments were received.
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4.0 ENVIRONMENTAL CONSIDERATION
This amendment involves changes.with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20, or changes a surveillance requirement. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding. Accordingly, this amendment meets the the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant-to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
5.0 CONCLUSION
We have concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: T. Bloxom J. Tatum Dated: October 26, 1990