ML13331A913
| ML13331A913 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 03/20/1987 |
| From: | Baskin K Southern California Edison Co |
| To: | |
| Shared Package | |
| ML13331A911 | List: |
| References | |
| NUDOCS 8703240580 | |
| Download: ML13331A913 (11) | |
Text
BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION Application of SOUTHERN 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 No. 139 Generating Station
)
SOUTHERN CALIFORNIA EDISON COMPANY and SAN DIEGO GAS & ELECTRIC COMPANY, pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 139.
This amendment consists of Proposed Change No. 155 to Provisional Operating License No. DPR-13. Proposed Change No. 155 modifies the Technical Specifications incorporated in Provisional Operating License No. DPR-13 as Appendix A.
Proposed Change No. 155 is a request to revise Technical Specification Section 4.3.1, Containment Testing, of Appendix A. The changes are primarily editorial in nature in order to clarify the applicable 10 CFR Part 50, Appendix 3, leak testing requirements for containment personnel airlocks.
In the event of conflict, the information in Amendment Application No. 139 supersedes the information previously submitted.
87O324O~eo B7oz2 PPD OADOCK 05000206 PDR
-2 Based on the safety analysis provided in the Description of Proposed Change and Safety Analysis, it is concluded that (1) the proposed change does not involve an unreviewed safety question as defined in 10 CFR 50.59, nor does 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, the fee of $150 is herewith remitted.
MJT:8145F
0 0
-3 Subscribed on this day of 24z4.4 1987.
Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY By:
~~PZ4 Kenneth P. Baskin Vice President Subscribed and sworn to before me this
_,__d day of 4
/ 77 7
OFFKCIAL SEAL AGNES CRABTREE Notary Public-California LOS ANGELES COUNTY My Comm. Exp. Sep. 14, 1990 Not y Public in 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 By:
0 0
-4 Subscribed on this 9 day of,7AZMC>49
, 1987.
Respectfully submitted, SAN DIEGO GAS & ELECTRIC COMPANY By:
3/C. Holcombe Vice President Subscribed and sworn to before me this day of
//1
/f'M OFFICIAL SEAL
- p.
JlLL QUlGLEY NOTARY PUBLIC - CALIFORNIA PRINCIPAL OFFICE IN SAN DIEGO COUNTY My Commission Exp. March 7, 1989 Not#
Public 'and efr e County of Sag(Diego, Stoe of Cali rnia My Commission Expires: J//1?
David R. Pigott Samuel B. Casey Orrick, Herrington & Sutcliffe Attorneys for San Diego Gas & Electric Company By:
David R. Pigott
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 Application No. 139 was served on the following by deposit in the United States Mail, postage prepaid, on the day of 1987.
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 L. G. Hinkleman 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
-2 James McGuffin Western Regional Manager Westinghouse Electric Corporation Post Office Box 2728 Pittsburgh, Pennsylvania 15230 A. I. Gaede P.O. Box 373 San Clemente, California 92672 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 ms A. Beoleftto
0*
DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NO. 155 TO THE TECHNICAL SPECIFICATIONS PROVISIONAL OPERATING LICENSE DPR-13 This is a request to revise Section 4.3.1, "Containment Testing" of Appendix A Technical Specifications for the San Onofre Nuclear Generating Station, Unit 1.
Existing Specification II.A.
Test Pressure Type B tests are conducted at a test pressure at or above 49.4 psig. In addition, the personnel airlocks are tested every six months at or above 49.4 psig. A lower pressure test, approximately 10 psig, will be used to test the personnel airlocks within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following an opening, except when the airlock is being used for multiple entries, then at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
II.C.
Test Schedule Type B tests, except for airlocks, are performed during every reactor shutdown for refueling, or other convenient intervals, but in no case at intervals greater than two years.
Airlock volumes between the doors are tested:
(1) at least every six months, and (2) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following each opening, except when the airlock is being used for multiple entries, then at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Proposed Specification II.A.
Test Pressure Type B tests are conducted at a test pressure at or above 49.4 psig.
Personnel airlocks are tested every six months at or above 49.4 psig. In addition, a lower pressure test at or above 3 psig is performed on the personnel airlocks as required by Section II.C.
-2 II.C.
Test Schedule Type B tests, except for airlocks, are performed during every reactor shutdown for refueling, or other convenient intervals, but in no case at intervals greater than two years.
Airlock volumes between the doors are tested:
(1) at least every six months at 49.4 psig, (2) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following each closing, except when the airlock is being used for multiple entries, then at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, at or above 3 psig test pressure*, and (3) prior to establishing CONTAINMENT INTEGRITY when maintenance has been performed on the airlock that could affect the airlock sealing capability at 49.4 psig.*
- Exemption to Appendix J of 10CFR50.
Description The proposed specification shown above involves four changes from the existing specification. The first change is an editorial change to Section A to remove references to the lower pressure test schedule and include this information in Section C. The second change consists of revising requirement (2) of Section C to specify each airlock shall be tested within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following each closing, versus each opening. For the reasons discussed in the next section, this change is also considered to be an editorial clarification. The third change consists of adding requirement (3) to test the airlock prior to establishing containment integrity if maintenance has been performed on the airlock which could affect the sealing capability. The fourth change consists of reducing the present lower pressure test from 10 psig to 3 psig. These proposed changes are being requested in order to provide clarification of the applicable 10 CFR Part 50, Appendix 3 airlock leak testing requirements.
The existing airlock leak testing requirements were incorporated into the Technical Specifications in February, 1985. As indicated in the Staff SER (dated February 8, 1985), Type B testing (including airlocks) is acceptable because it is in accordance with the provisions of Paragraph III.B.2, III.D.2(b)(i) and III.D.2(b)(iii) of Appendix J. However, our proposed submittal, and the Staff SER, did not address Paragraph III.D.2(b)(ii) of Appendix J. This section requires performing a peak pressure test on airlocks opened during periods when containment integrity is not required by the Technical Specifications (i.e., Modes 5 and 6). In light of the omission of this requirement in the Technical Specifications, and lack of any reference thereto by the staff SER, it is our intention to abide by the Appendix J requirement as necessary. However, the above described proposed specification is submitted to request an exemption to this Appendix 3 requirement, and proposed specifications are similar to the Westinghouse STS.
-3 Reason for the Change During plant operation, situations arise which require the plant to be brought to cold shutdown (Mode 5) for short periods of time to perform plant maintenance, repairs, etc. If containment entry through the personnel airlocks is necessary, airlock testing in accordance with the current Technical Specifications would consist of a 10 psig leak test within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the opening. Appendix 3, however, would require a higher pressure test (49.4 psig - denoted as Pa) prior to Mode 4 entry in accordance with Section III.D.2.
This section of Appendix 3 specifies airlocks opened during periods when containment integrity is not required by the plant's Technical Specifications (i.e., Modes 5 and
- 6) shall be tested at the end of such periods (prior to Mode 4 entry) at not less than Pa. The proposed specification allows the flexibility to maintain containment integrity while in Mode 5 by performing the lower pressure test every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. A Pa test would be required only if maintenance is performed on the airlock that could affect the sealing capability.
The revision to require testing within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following each closing instead of each opening is proposed to clarify the necessary testing requirements when containment integrity is not established and the personnel airlock doors are open continuously. Clearly the intent of the existing specification is not to require testing every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> when containment integrity is not intact. Therefore, these words have been revised to indicate testing shall be performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of each closure as required by the standard technical specification.
The proposed change reduces the magnitude of the lower pressure test from 10 psig to 3 psig. The forces exerted on the inner air lock door at the existing test pressure are excessive and potentially damaging to the door mechanism. The latching force necessary to oppose the opening force on the door during the 10 psig test is far greater than necessary for routine door operation.
The lower pressure test places a force on the inner door in a direction opposite that which would occur during accident conditions.
The test force direction tends to lift the door off of the gasket. The door manufacturer has performed calculations indicating that the 3 psig test exerts a greater unseating force on the door than a Pa test would when applied to the testable seal of a door equipped with a testable seal.
Accident pressure applies a force in a direction tending to seat the door onto the gasket, resulting in a tighter seal.
The purpose of the lower pressure test is to assure proper sealing of the door after its use.
Leakage test methods are adequate to accomplish this objective with a 3 psig test pressure. Reducing the lower pressure from 10 psig to 3 psig will avoid placing unnecessary stress on the door mechanism on a regular basis while still providing assurances that the doors are sealed after use.
-4 Safety Analysis The proposed change discussed above is deemed not to involve a significant hazards consideration based on the determination that the change constitutes an additional control not presently included in the Technical Specifications. This determination shall be changed if there is a positive finding in any one of the following areas:
- 1. Will operation of the facility in accordance with the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The basis for airlock leak testing is to detect deterioration of sealing capability in order to prevent excessive dose consequences from a reactor transient. Incorporation of an additional testing requirement will provide clarification for airlock testing in situations not covered by the existing Technical Specifications.
Notwithstanding the fact that this additional testing requirement is taking exception to the Appendix 3 requirement, the proposed test will enhance the reliability of the airlock sealing capability by ensuring appropriate testing is conducted when necessary. Reducing the lower pressure test to 3 psig will decrease the potential for damage to the door closing mechanism caused by testing the door at it's design limit for reverse pressure. Accident consequences or probability will not be increased since containment pressure will seal the inner door.
Based on the foregoing, operation of the facility in accordance with the proposed change will not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Will operation of the facility in accordance with the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No The function of the airlock is to provide personnel access to containment as necessary during periods when containment integrity is required. Airlock leak testing is performed to verify the leakage integrity of the airlock on a periodic basis, subsequent to use, and subsequent to modifications which could affect the sealing capability. Testing in accordance with the proposed specifications will ensure that the integrity of the airlock is maintained under all circumstances encountered during plant operation. Frequency of air lock testing will not change as a result of this proposed change. Reducing the lower test pressure from 10 psig to 3 psig ensures the inner door will be sealed and the latching mechanism will not be damaged.
Therefore, operation of the facility in accordance with the proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.
-5
- 3. Will operation of the facility in accordance with the proposed change involve a significant reduction in a margin of safety?
Response: No The margin of safety for the airlock is defined by the sealing capability in the event of a reactor transient. The proposed change is intending to ensure that adequate leak testing requirements are included in the Technical Specifications. By including these requirements in the Technical Specifications the sealing capability of the airlock will be maintained. Reduction of the lower test pressure from 10 psig to 3 psig does not affect the margin of safety since the direction of test is opposite the pressure direction resulting from the accident. Testing at 3 psig ensures the door mechanism has latched and the door is sealed.
Accordingly, operation of the facility in accordance with the proposed change will not involve a significant reduction in a margin of safety.
Safety and Significant Hazards Consideration Determination Based on the Safety Analysis, it is concluded that: (1) the proposed change does not constitute a significant hazards consideration as defined by 10 CFR 50.92; and (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 or the environment as described in the NRC Environmental Statement.
8685u:8125F:9184u