ML13331A834
| ML13331A834 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/20/1985 |
| From: | Dietch R Southern California Edison Co |
| To: | |
| Shared Package | |
| ML13331A833 | List: |
| References | |
| NUDOCS 8512040099 | |
| Download: ML13331A834 (14) | |
Text
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BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION Application of SOfJTHERN CALIFORNIA EDISON
)
COMPANY and SAN DIEGO GAS & ELECTRIC COMPANY for a Class 104(b) License to Acquire,
)
DOCKET NO. 50-206 Possess, and Use a Utilization Facility as Part of Unit No. 1 of the San Onofre Nuclear )
Amendment Application No. 132 Generating Station SOUTHERN CALIFORNIA EDISON COMPANY and SAN DIEGO GAS & ELECTRIC COMPANY, pursuant to 10 CFR 50.90, hereby submit Amendment No. 132.
This amendment consists of Proposed Change No. 156 to the Technical Specifications incorporated in Provisional Operating License No. DPR-13 as Appendices A and B.
Proposed Change No. 156 will replace Technical Specification 4.2.3, "Safety Injection System Hydraulic Valve Testing (Surveillance Requirement)"
with a revision to Specification 4.2.1, "Safety Injection and Containment Spray System Periodic Testing."
In the event of conflict, the information in Amendment Application No. 132 supersedes the information previously submitted.
Based on the safety analysis provided in the Description of Proposed Change and Safety Analysis, it is concluded that (1) this proposed change does not involve an unreviewed safety question as defined in 10 CFR 50.59, nor does 9512040099 951121.
PDR ADOCK 05000206 P
-2 it present significant hazards considerations not described or implicit in the Final Safety Analysis, and (2) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed change.
Pursuant to 10 CFR 170.12, as revised in 49 FR 21293 dated May 21, 1984, the review of the Proposed Change contained in Amendment Application No. 132 has been determined to require a fee of $150.00.
The fee of $150.00 is herewith remitted.
GEH:5392F
-3 Subscribed on this --4) day of ALj4.,-
5 kr Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY By Robert Dietch Vice President Subscribed and sworn to before me this 0c day of A
ffRK.
OFFICIAL, SEAL C SALLY SEBO NOTARY PUBLIC - CALIFORNIA LOS ANGELES COUNTY
",7 My comm. expires APR 14, 1986 Notary Public 1 and for the County of Los Angeles, State of California My Commission Expires:
Charles R. Kocher James A. Beoletto Attorneys for Southern California Edison Company Jam"A Beoletto
@0e
-4 Subscribed on this 15 day of OVaod9e7/ /
-i' Respectfully submitted, SAN DIEGO GAS & ELECTRIC COMPANY By
/7. C. Holcombe Vice President Subscribed and sworn to before me this
/
day of ff
/?Jf.
OFFICIAL SEA JILL QUIGLEY NOTARY PUBUIC-CAUIFORNIA
,PRINCIPAL OFFICE IN SAN DIEGO COUNTY My Commission Exp. March 7, 1989 No d-ry Public Wand f0 thpyt'ounty of an Diego, St e of Califoria My Commission Expires:
4 I'
David R. Pigott Samuel B. Casey Orrick, Herrington & Sutcliffe Attorneys for San Diego Gas & Electric Company By David R. Pigott
@0*
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of SOUTHERN CALIFORNIA EDISON COMPANY and SAN DIEGO GAS & ELECTRIC Docket No. 50-206 COMPANY (San Onofre Nuclear Generating Station Unit No. 1 CERTIFICATE OF SERVICE I hereby certify that a copy of Amendment No. 132 was served on the following by deposit in the United States Mail, postage prepaid, on the 21st day of November
,1985.
Henry J. McGurren, Esq.
Staff Counsel U.S. Nuclear Regulatory Commission Washington, D.C.
20545 David R. Pigott, Esq.
Samuel B. Casey, Esq.
Orrick, Herrington & Sutcliffe 600 Montgomery Street San Francisco, California 94111 John V. Morowski Bechtel Power Corporation P.O. Box 60860, Terminal Annex Los Angeles, California 90060 Michael L. Mellor, Esq.
Thelen, Marrin, Johnson & Bridges Two Embarcadero Center San Francisco, California 94111 Huey Johnson Secretary for Resources State of California 1416 Ninth Street Sacramento, California 95814 Janice E. Kerr, General Counsel California Public Utilities Commission 5066 State Building San Francisco, California 94102
te.**
-2
- 3. Rengel Atomic Power Division Westinghouse Electric Corporation Box 355 Pittsburgh, Pennsylvania 15230 A. I. Gaede 23222 Cheswald Laguna Nigel, California 92677 Frederick E. John, Executive Director California Public Utilities Commission 5050 State Building San Francisco, California 94102 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Ja es A. Beot o As stant Counsel Sou rn California Edison Company
Description of Proposed Change No. 156 and Safety Evaluation Provisional Operating License DPR-13 This is a request to revise Sections 4.2.1, "Safety Injection and Containment Spray System Periodic Testing," and 4.2.3, "Safety Injection System Hydraulic Valve Testing (Surveillance Requirement)" of San Onofre Unit 1 Provisional Operating License DPR-13 Appendix A Technical Specifications.
Description Section 4.2.3 of the Technical Specifications includes provisions for interim surveillance of the San Onofre Unit 1 Safety Injection System (SIS).
The specification includes a provision to establish a long-term program. This proposed change replaces the interim program which requires plant shutdown every 92 days with an addition to the periodic system testing of specification 4.2.1. to this proposed change supports the replacement of the hot SIS functional test with an additional provision in specification 4.2.1 to verify valve travel within the time required by the safety analysis.
Existing Specification is a copy of existing specifications 4.2.1 "Safety Injection and Containment Spray System Periodic Testing," and 4.2.3, "Safety Injection System Hydraulic Valve Testing (Surveillance Requirement).
Proposed Specification is a copy of the revised sections.
Safety Evaluation The proposed change discussed above is determined not to constitute a significant hazards consideration as it does not degrade plant safety.
The interim program was instituted in order to verify the success of modifications made during the September 3, 1981 SIS outage. Attachment 3 provides the results of the tests performed to date which demonstrate acceptable valve performance. The responses to the following questions further support this conclusion:
- 1. Question Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
-2
Response
No This change eliminates the interim SIS surveillance requirement established to verify the success of modifications performed in September 1981. provides a summary of the results of the testing and documents the success of the modifications. Since SIS performance is not degraded there is no impact on any safety analysis involving the need for safety injection.
- 2. Question Will operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident?
Response: No The changes in these specifications do not involve any changes in SIS performance characteristics. The system will continue to be available to perform its safety function as described in the Final Safety Analysis.
- 3. Question Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?
Response
No Since no changes to the Safety Injection System are associated with this change, there will be no change in a margin of safety.
This proposed change is similar to example (iv) of the "Examples of Amendments That are Considered Not Likely to Involve Significant Hazards Considerations" as published in 48 FR 14864 dated April 6, 1983.
Example (iv) states:
A relief granted upon demonstration of acceptable operation from an operating restriction that was imposed because acceptable operation was not yet demonstrated. This assumes that the operating restriction and the criteria to.be applied to a request for relief have been established in a prior review and that it is justified in a satisfactory way that the criteria have been met.
The existing specification is similar to this example because it is an "interim" program designed to demonstrate by special test the acceptability of the modified Safety Injection System. The revision to specification 4.2.1 provides continuing assurance of acceptable SIS performance.
-3 Safety and Signift-cant Hazards Determination Based on the safefy analysis, it is concluded that:
- 1. the Proposed Change does not constitute a significant hazards consideration as defined by 10 CFR 50.92;
- 2. there is reasonable assurance that the health and safety of the public will not be endangered by the proposed change; and
- 3. this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Environmental Statement.
GEH:5108F
ATTACHMENT 1 EXISTING SPECIFICATIONS
ATTACHMENT 1 4.2 SAFETY INJECTION AND CONTAINMENT SPRAY SYSTEM 4.2.1 SAFETY INJECTION AND CONTAINMENT SPRAY SYSTEM PERIODIC TESTING APPLICABILITY:
Applies to testing of the Safety Injection System and the Containment Spray System.
OBJECTIVE:
To verify that the Safety Injection System and the Containment Spray System will respond promptly and properly if required.
SPECIFICATION:
I. System Test A. Safety Injection System (1) During reactor shutdown at intervals not longer than the normal plant refueling intervals, a "no-flow" system test shall be conducted to demonstrate proper availability of the system. The test shall be per formed in accordance with the following procedure:
(a) The feedwater, safety injection, charging, condensate, and heater drain pumps shall not be operating. Their respective breakers shall be racked-out to the test position with control power available.
(b) The flow path for condensate shall be positively blocked prior to the test.
(c) Injection and recirculation system operation shall be initiated by instrumentation and controls installed in the control room.
(2) The test will be considered satisfactory if control board indication and visual observations indicate all components have operated and sequenced properly. That is, the appropriate pump breakers have opened and closed, and all valves have completed their travel.
(3) A test of the trisodium phosphate additive shall be conducted to demonstrate the availability of the system. The test shall be performed in accordance with the following procedure:
(a) The three (3) storage racks are visually observed to have maintained their integrity.
(b) The three (3) racks, each with a storage capacity of 1800 pounds of anhydrous trisodium phosphate additive, are visually observed to be full.
Page 2 of ATTACHMENT 1 BASIS:
The Safety Injection System is a principal plant safeguard. It provides means to insert negatiie reactivity and cm damage in the event of a loss of coolant or steam break accident.
Preoperational performance tests of the components are performed in the manufacturer's shop.
An initial system flow test demonstrates proper dynamic functioning of the system. Thereafter, periodic tests demonstrate that all components are functioning properly. For these tests, flow through the system is not required.
The tests specified above will demonstrate that all components which do not normally and routinely operate will operate properly and in sequence if required. The portion of the Recirculation system outside the containment sphere is effectively an extension of the boundary of the containment.
The measurement of the recirculation loop leakage ensures that the calculated EAB 0-2 hr. thyroid dose does not exceed 10 CFR 100 limits.
The trisodium phosphate stored in storage racks located in the containment is provided to minimize the possibility of stress corrosion cracking of metal components during operation of the ECCS following a LOCA.
The trisodium phosphate provides this protection by dissolving in the sump water and causing its final pH to be raised to 7.0 -
7.5.
The requirement to dissolve trisodium phosphate from one of the sample storage racks in distilled water heated and borated, to the extent recirculating post LOCA sump water is projected to be heated and borated, provides assurance that the stored trisodium phosphate will dissolve as required following a LOCA. The sample storage racks are sized to contain 0.5 pounds of trisodium phosphate. Trisodium phosphate stored in the sample storage racks has a surface area to volume ratio of 1.33 whereas the trisodium phosphate stored in the main racks has a surface area to volume ratio of 1.15.
Visual inspection of the non-redundant piping in the Containment Spray System provides additional assurance of the integrity of that system.
References:
(1)
Final Engineering Report and Safety Analysis, Paragraph 5.1.
(2)
"San Onofre Nuclear Generating Station", report forwarded by letter dated December 29, 1971 from Jack B. Moore to Director, Division of Reactor Licensing, USAEC, subject:
Emergency Core Cooling System Performance, San Onofre Nuclear Generating Station, Unit 1.
(3)
USAEC Safety Evaluation of ECCS Performance Analysis for San Onofre Unit.1, forwarded by letter dated March 6, 1974 from Mr. Dbnald J. Skovholt to Mr. Jack B. Moore.
page 3 of ATTACHMENT i 4.2.3 SAFETY INJECTION SYSTEM HYDRAULIC VALVE TESTING (SURVEILLANCE REQUIREMENT)
An interim surveillance testing program shall be conducted during the remainder of the current fuel cycle which began in June 1981.
At the next refueling outage, the interim program shall be supplanted by a long term surveillance testing program.
It is intended that this long term program will be developed and submitted to the NRC for review and approval at least 60 days prior to the next refueling outage.
The interim surveillance program shall be as follows:
- 1.
At least once every 92 days, (except when the inverval lapses while in mode 5 or 6, in which case the test may be delayed until a mode 3 or 4 operation prior to the next entry into mode 2) the unit shall be placed in mode 3 or 4 and a Hot SIS functional test (with the MOV-850 A, B&C valves locked closed) shall be performed. This test shall include a determination of the force required to open valves HV-851 A&B and the margin to available actuation force.
This test shall be evaluated on the basis of the following criteria:
- a. If the measured actuator force for both the HV-851 A&B valves is less than 10,000 lbf*, the unit may be returned to power.
- b. If the measured actuator force of either HV-851 A or B is between 10,000 and 22,000 lbf, the Hot SIS test for both valves shall be repeated to again determine required opening force and available margin. The prediction will assume a straight line extrapolation from the following equation:
(22,000 -
F 2)
TF)/
(F1 -
F)/T where Fl measured actuator force from the first Hot SIS test during the current surveillance test (lbf)
F2 - measured actuator force from the second Hot SIS test during the current surveillance test (lbf)
- Upon receipt of satisfactory data from continuing testing and analysis, the NRC staff will consider a request from Southern California Edison Company to change this number to more accurately reflect existing conditions.
page 4 of ATTACHMENT 1 TL =time (in days) since the last surveillance testing F = the actuator force from the previous surveillance test (lbf)*
If the calculated value of T does not exceed 92 days, the next surveillance test must be performed before T days had elapsed.
- c. If the measured actuator force of either HV-851 A or 8 is greater than 22,000 lbf, the valve(s) shall be declared inoperable. Test results shall be reported to the NRC along with proposed corrective actions and NRC approval obtained prior to returning the unit to service.
- 2.
The first test shall be performed not less than 14 days nor more than 21 days following return to power from the current outage which began September 3, 1981.
- For the first surveillance test, the value of F shall be the average actuator force of HV-851 A&B valves from pre-operation testing (3135 lbf).'
All subsequent surveillance testing shall assume the F2 value from the previous surveillance test for each valve. If an F2 was not required during the previous surveillance test, the F1 value for each valve shall be assumed.