ML13331A945
| ML13331A945 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/20/1987 |
| From: | Baskin K, Beoletto J, Holcombe J SAN DIEGO GAS & ELECTRIC CO., SOUTHERN CALIFORNIA EDISON CO. |
| To: | |
| Shared Package | |
| ML13331A944 | List: |
| References | |
| NUDOCS 8707280069 | |
| Download: ML13331A945 (12) | |
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. 142 Generating Station
)
SOUTHERN CALIFORNIA EDISON COMPANY and SAN DIEGO GAS & ELECTRIC COMPANY, pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 142.
This amendment consists of Proposed Change No. 179 to Provisional Operating License No. DPR-13. Proposed Change No. 179 modifies the Technical Specifications incorporated in Provisional Operating License No. DPR-13 as Appendix A.
Proposed Change No. 179 is a request to revise Technical Specification Sections 4.2.1, Safety Injection and Containment Spray Periodic Testing and 4.2.3, Safety Injection System Hydraulic Valve Testing (Surveillance Requirement) of Appendix A. The changes are proposed to respond to NRC staff comments on previously submitted Proposed Change No. 156. The change eliminates an interim specification for Safety Injection System Testing and supplants it with a long term program.
7O72A0069 870720 P
-2 In the event of conflict, the information in Amendment Application No. 142 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) 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.
GEH:8676F
-3 Subscribed on this ag2 day of
, 1987.
Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY By Kenneth P. Baskin Vice President Subscribed and sworn to before me this
,a-84 day of
/f'.
OFFICIAL 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:
)yiz/Z/ff Charles R. Kocher James A. Beoletto Attorneys for Southern California Edison Company By:
Ja A. Beoletto
-4 Subscribed on this _
day of
, 1987.
Respectfully submitted, SAN DIEGO GAS & ELECTRIC COMPANY By: )< C. *Holcombec Vice President Subscribed and sworn to before me this 0-adyofoe Im ary Pubwin af fthe County of an Diego4-tate C
faAornia My Commission Expires: Ag.
Z19/.f OFFICIAL SEAL JILL QUIGLEY NOTARY PUBLIC-CALIFORNIA David R. Pigott PRINCIPAL OFFICE IN Samuel B. Casey SAN DIEGO COUNTY MyCommissionExp.March7,1989 Orrick, Herrington & Sutcliffe Attorneys for San Diego Gas & Electric Company By:
C41 g 7" '
David R. Pigott
9 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. 142 was served on the following by deposit in the United States Mail, postage prepaid, on the 20th day of
.Ily
, 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 23222 Cheswald Drive Laguna Niguel, 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 me7s A. -BeolettoN
9 DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NO. 179 TO THE TECHNICAL SPECIFICATIONS PROVISIONAL OPERATING LICENSE NO. DPR-13 This is a request to revise Section 4.2.1, "Safety Injection and Containment Spray System Periodic Testing" and delete Section 4.2.3, "Safety Injection System Hydraulic Valve Testing (Surveillance Requirement)," of Appendix A Technical Specifications for San Onofre Nuclear Generating Station Unit 1.
DESCRIPTION Technical Specification (T.S.) 4.2.3, "Safety Injection System Hydraulic Valve Testing (Surveillance Requirement)" was developed in 1981 in response to the common mode failure event of two Safety Injection System (SIS) hydraulic valves. Several modifications were made following the event to eliminate the cause of the common mode failure and T.S. 4.2.3 was established to verify the success of the modifications particularly with regard to the effects of long-term set of the valve seat faces. T.S. 4.2.3 was an interim requirement for one fuel cycle only. Technical Specification 4.2.1, "Safety Injection and Containment Spray System Periodic Testing," is the normal surveillance requirement for the same system. This Proposed Change eliminates the interim T.S. 4.2.3 and modifies T.S. 4.2.1 to establish a long term program to verify SIS performance.
SCE had previously submitted Proposed Change No. 156 to the Technical Specifications as License Amendment Application No. 132 (submitted on November 20, 1985).
That proposed change would have eliminated T.S. 4.2.3 and modified T.S. 4.2.1 by the addition of a timing requirement for the valve stroke times of Hydraulic Valves (HV's) 851A and B. The NRC had questions on SCE's submittal which led to additional information being submitted by SCE letters dated March 26, 1986 and June 25, 1986. The NRC denied SCE's License Amendment Application No. 132 by NRC letter dated March 30, 1987.
The NRC's denial of Proposed Change No. 156 was based on their determination that the effects of long-term set of the valve seat faces was not adequately addressed. This Proposed Change is intended to incorporate the NRC's comments by establishing a "Hot-SIS" test that would not only perform the testing required by the current T.S. 4.2.1 (as part of the new, modified testing required by proposed T.S. 4.2.1), but would also provide the required verification of HV's 851A and B operation under simulated SI conditions considering the effect of long-term set.
The modification of T.S. 4.2.1 proposed herein uses the previous interim T.S.
4.2.3 with some modifications.
The modifications to the previous T.S. 4.2.3 are as follows:
-2
- 1. The proposed test does not require the MOV 850 A, B and C valves to be locked closed.
The test will now be required to be performed with RCS pressure conditions that will preclude actual delivery to the RCS of the SIS borated water. The Safety Injection/Feedwater Pumps shutoff head in the safety injection mode is on the order of 1300 psi.
By requiring the test to be performed while RCS pressure exceeds 1500 psi, actual injection is precluded. The advantage of performing the test this way is that the SIS will not be required to be taken out of service (by locking closed MOV's 850 A, B and C) for the duration of the test.
- 2. The proposed test uses an equation to determine future test intervals (when the value of actuator force is not less than or equal to 10,000 lbf) that is similar to that used in the interim T.S. 4.2.3.
The new equation requires that the interval between tests be reduced by an amount directly proportional to the degree by which the actuator force exceeds 10,000 lbf.
As before, if the actuator force exceeds 22,000 lbf, the valve is declared inoperable and NRC approval is required prior to restart.
The equation is different from the previous one because it does not require the performance of a second test during the surveillance if the actuator force of the first test exceeds 10,000 lbf.
This is because the phenomenon which is being monitored is proportional to the amount of time the valve seat faces are in contact under high differential pressure conditions and because the first performance of the test would cause the valve seats to come apart, eliminating any long-term set. In the basis of the specification it is suggested that the test be performed prior to stopping the feedwater pumps during the process of shutting down. This suggestion is made because stopping the pumps may allow the valves to unseat due to backpressure in the SI lines which would eliminate long-term set.
While it is also true that this may happen during the period in the test when the feedwater pumps are being stopped, this occurs in a very short time interval and it may not lower pressure enough to cause the valves to unseat. The suggestion for doing the test prior to stopping the feedwater pumps is not in the T.S. itself due to the possibility of conditions which may preclude it.
- 3. The test interval has been changed to require the test to be performed when the plant is being shut down from MODE 1 to MODE 5 and while in Mode 3 but not more frequently than once every nine months.
Should there be a fuel cycle with no planned MODE 5 outages, the test would therefore be required only at a refueling interval.
The result of this proposed change will be the elimination of the interim 92 day interval Hot-SIS test and the modification of existing T.S. 4.2.1 "no-flow" test to continue to verify component sequencing while at the same time verifying proper functioning of the HV 851A and B valves under simulated SI conditions. The name of the test has been changed from a "no-flow" test to a "Hot-SIS Test" to accurately describe the conditions of the new test.
9
-3 Additional administrative changes are made in the T.S. format to both facilitate its use and to make it more consistent with the provisions of T.S.
4.0.1 and 4.0.4 issued by NRC Amendment No. 83 on November 2, 1984.
EXISTING TECHNICAL SPECIFICATION(S)
See Attachment 1 PROPOSED TECHNICAL SPECIFICATION(S)
See Attachment 2 SAFETY EVALUATION The proposed change discussed above shall be deemed to constitute a significant hazards consideration if there is a positive finding in any of the following areas:
- 1. 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?
Response: No This change will not significantly increase the probability or consequences of an accident previously evaluated.
The performance of this test will require the SIS to perform as if actually needed. All valves will sequence and the pumps will stop and/or stop and restart as required. The MOV 850 A, B and C valves will all open as part of this test whereas they were not required to open in the interim test. This change allows the SIS to remain in service during the test. This was not the case previously since when the NOV's are locked closed the SIS cannot deliver the necessary flow to the core should an actual event occur. Opening the MOV 850 A, B and C valves will not significantly increase the probability of an inter-system LOCA due to the check valves downstream of the MOV 850 A, B and C valves and the check valves at the discharge of the feedwater pumps. In any case, the advantage of having SI available during the test outweighs the small increase in the probability of an intersystem LOCA.
This proposed change will require an enhanced surveillance program to assure and confirm long-term system operability. One of the problems identified as causing the 1981 valve failures was long-term set of the valve seat faces.
The interim 92 day interval hot SIS test was designed to provide, among other things, continuing assurance that the actuators had adequate margin to overcome the effect of long-term set. The results of the interim test program were summarized in Amendment Application No. 132 submitted by SCE letter dated November 20, 1985. The conclusion was that the actuators now have adequate margin to account for this phenomenon.
-4 This proposed change provides a long-term program which will increase the time between tests and provide continuing assurance that the valves will perform their function under simulated conditions. Long-term set which may have occurred after 92 days will now be monitored for its effect after longer periods on the order of 9 months.
The changes in the equation to determine testing frequency will require more frequent testing if actuator force is between 10,000 lbf and 22,000 lbf.
Elimination of the interim T.S., 4.2.3, is merely administrative in nature since the provisions of the specification expired at the refueling outage which began in November 1985.
Therefore, it is concluded that operation of the facility in accordance with this proposed change will not cause a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Will operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No This change modifies an existing surveillance requirement (T.S. 4.2.1) on the SIS to include a surveillance that was previously done at 92 day intervals. Since a similar test has previously been performed and since it is a surveillance test intended to assure system operability, no new accidents will be created. The remaining changes are purely administrative and do not affect any type of accident. Therefore, it is concluded that operation of the facility in accordance with this proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?
Response: No The facility's margin of safety will not be decreased but will be increased by having increased and more rigorous surveillance of this safety system. No system setpoints or operating parameters are being changed. The negative effect of the increased surveillance will be increased maintenance and outage time, though this will be minimized due to the test being done as the unit is being shut down for a planned MODE 5 operation. The remaining changes are purely administrative and do not affect a margin of safety. Therefore, it is concluded that operation of the facility in accordance with this proposed change does not involve a significant reduction in a margin of safety.
e0
-5 The Commission has provided guidance concerning the application of the standards for determining whether a significant hazard exists by providing certain examples (48 FR 14870) of amendments that are considered not likely to involve significant hazards considerations. Examples (i and ii) related to (1) a purely administrative change to technical specifications and (2) a change that constitutes an additional limitation, restriction, or control not presently included in the technical specifications are similar to this change because it includes a more stringent surveillance requirement and administrative changes.
SAFETY AND SIGNIFICANT HAZARDS DETERMINATION Based on the safety evaluation, 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 on the environment as described in the NRC Environmental Statement.
GEH:8336F
ATTACHMENT 1