ML13331B015
| ML13331B015 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 02/26/1988 |
| From: | Baskin K Southern California Edison Co |
| To: | |
| Shared Package | |
| ML13331B014 | List: |
| References | |
| NUDOCS 8803080093 | |
| Download: ML13331B015 (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. I of the San Onofre Nuclear )
Amendment No. 147 Generating Station
)
SOUTHERN CALIFORNIA EDISON COMPANY and SAN DIEGO GAS & ELECTRIC COMPANY, pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 147.
This amendment consists of Proposed Change No.
f4)to Provisional Operating License No. DPR-13. Proposed Change No. 1*4 modifies the Technical Specifications incorporated in Provisional Operating License No. DPR-13 as Appendix A.
Proposed Change No. 174 revises Technical Specifications 3.5.5, Containment Isolation Instrumentation; 3.5.8, Radioactive Liquid Effluent Instrumentation; 3.5.9, Radioactive Gaseous Process and Effluent Monitoring Instrumentation and 4.1.3, Radioactive Gaseous Process and Effluent Monitoring Instrumentation. The changes are specific to each of the technical specifications affected. They provide clarification and relief for plant operation.
Specification 3.5.5 is revised to exempt the Containment Radioactivity-High from Specification 3.0.4 and to clarify that there is not a single manual actuation switch for all five purge and exhaust valves.
Specification 3.5.8 is revised in the action statement to allow for a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 8803080093 880226 PDR ADOCK 05000206 p
-2 sample collection and a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> analysis for inoperable Turbine Building and Yard Sump monitors.
Specifications 3.5.9, 4.1.2 and 4.1.3 are revised to provide clarification on the operational requirements of specific radiation monitors.
In the event of conflict, the information in Amendment Application No. 147 supersedes the information previously submitted.
Based on the safety evaluation provided in the Description and Safety Analysis of Proposed Change No. 174, 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.
-3 Subscribed on this 16' day of }AL7
, 1988.
Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY Kenneth P. Bas n Vice President Subscribed and sworn tp before me this
,@t day of
_________f__.
Not Pubfic in and for the County of Los Angeles, State of California My Commission Expires:
OFFICIAL SEAL AGNES Ci;ABTREE Notary Public-California Charles R. Kocher LOSANGELESCOUNTY James A. Beoletto My Comm. Exp. Sep. 14,1990 Attorneys for Southern California Edison Company By:
F 61 m
A. Beolet o
-4 Subscribed on this 6
day of 5 AboL
, 1988.
Respectfully submitted, SAN DIEGO GAS & ELECTRIC COMPANY By:
G. D.Cotton Ve President Subscribed and sworn to before me this d
day of
_4_LAAA OFFICIAL SEAL STEPHANIE E. HITT NOTARY PUBLICCALIFORNIA PRINCIPAL OFFICE IN SAN DIEGO COUNTY VYWW Exp Aug& 30 1991 Notary Puflic in and for the County of San Diego, State of California My Commission Expires:
e8 O
I 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
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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. 147 was served on the following by deposit in the United States Mail, postage prepaid, on the 29th day of Fehrary 9 1988.
Henry 3. 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 ames A.Beole-~ o
DESCRIPTION OF PROPOSED CHANGE NO. 174 AND SAFETY EVALUATION This is a request to revise Appendix A Technical Specifications 3.5.5, Containment Isolation Instrumentation; 3.5.8, Radioactive Liquid Effluent Instrumentation; 3.5.9, Radioactive Gaseous Process and Effluent Monitoring Instrumentation; 4.1.2, Radioactive Liquid Effluent Instrumentation; and 4.1.3, Radioactive Gaseous Process and Effluent Monitoring Instrumentation.
Description Proposed Change No. 174 revises the Containment Radioactivity-High instrumentation of Table 3.5.5-1 of Technical Specification 3.5.5. In Table 3.5.5-1 an asterisk is added to the ACTION for the Containment Radioactivity-High. This asterisk indicates in the Table Notation that the provisions of Specification 3.0.4 are not applicable. Specification 3.0.4 prevents entry into an operational mode if a Limiting Condition for Operation (LCO) is being satisfied by an Action Statement. The Action Statement for Containment Radioactivity-High indicates that operation may continue provided the containment purge and exhaust valves are maintained closed in the event the channel is declared inoperable. The containment purge and exhaust valves are maintained closed at all times during Modes 1-4. It is inappropriate that declaring the Containment Radioactivity-High channel inoperable prior to entering an operational mode where it is required should prevent the plant from entering the operational mode since the containment purge and exhaust valves are always maintained closed during Modes 1-4 regardless of the Action Statement conditions.
Proposed Change No. 174 revises Action Statement 18 of Technical Specification 3.5.8 to allow for a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> collection and a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> analysis period, versus a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> collection and analysis, in the event that the instrument channel for the Turbine Building Sump or the Yard Sump is declared inoperable. The purpose of this revision is to provide additional time to perform the analysis. These sumps receive leak-offs from equipment and drains throughout the plant. Since there are no normal potential sources of highly radioactive effluents which would be transmitted to these sumps, it is not expected that this release path would exhibit high activities which would require some additional actions. Rather, grab sample activity levels which are considered insignificant are expected in this release path. Extending the time period for performing the analysis of samples taken from this effluent pathway makes it commensurate with the importance of this pathway and consistent with the analysis time for other similar pathways. Other effluent pathways which allow for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> analysis time include the stack gross activity and the stack noble gas monitors. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time period for analysis will also provide relief and an adequate time to ensure the analysis is performed within the Action Statement time period.
-2 Proposed Change No. 174 revises Table 3.5.9.1 of Technical Specification 3.5.9 and Table 4.1.3.1 of Technical Specification 4.1.3 to explicitly indicate the flow rate measuring devices used for measuring flow to the radiation monitors. Flow to monitor R1219 can be measured by flow device 1220 or 1221 and flow to monitor R1211 is measured by flow device 1212; flow to the other monitors (R1212, R1220, R1221 and R1254) are measured by flow devices with the same number designation as is used for the radiation monitor. The footnote to the Sampler Flow Rate Measuring Device Technical Specification is to clarify that the flow rate measuring device is not a single device used to measure the stack flow, but rather four separate measuring devices which are used to measure flow through the radiation monitors.
Proposed Change No. 174 revises Table 4.1.2.1 of Technical Specification 4.1.2 to indicate that only one flow element is required for the instrumentation surveillance. The purpose of this revision is to allow a Channel Check of the appropriate instrument. Both flow elements, FE-16 and FE-18, are capable of monitoring the Liquid Radwaste Effluent Line depending on the flowrate. Since one flow element is used to monitor the flow, requiring a Channel Check of the unused flow element is unnecessary. A Channel Check of the unused flow element will provide inaccurate information on the effluent flow rate.
Therefore, replacing "FE-16 and FE-18" with "FE-16, FE-18" as in Table 3.5.8.1 will resolve this concern.
Proposed Change No. 174 revises Table 3.5.9.1 of Technical Specification 3.5.9 and Table 4.1.3.1 of Technical Specification 4.1.3 to delete the single asterisk and associated note. The note indicates the radiation monitor affected does not perform an isolation function and does not have a control room alarm. These functions are performed by the monitor; therefore, the note will be deleted. In addition a transfer select switch is being added to the controls for the Waste Gas Holdup System during the midcycle outage. This switch will allow the operator to select R-1219 the current monitor for the system or R-1254. As a result footnote (2) is being added to R-1254 under the Noble Gas Activity Monitor to indicate it can also provide auto-termination of the release from the Waste Gas Holdup System.
Proposed Change No. 174 revises Table 3.5.9.1 of Technical Specification 3.5.9 and Table 4.1.3.1 of Technical Specification 4.1.3 to delete R-1214 the stack gross activity monitor. Due to the age and difficulty in calibration and maintenance of the monitor it is being removed from the technical specifications. Monitors R-1219, 1220 and 1221 will provide the function performed by R-1214. As a result "(R-1219, 1220 and 1221)" will be included under the Gross Activity Monitors and the note indicated by the "*"
associated with R-1214 will be deleted.
Proposed Change No. 174 revises Table 3.5.5-1 item a) "Manual" under Purge and Exhaust Isolation. In order to clarify that the "1" under Total No. of Channels, Channels to Trip and Minimum Channels Operable refers to the manual actuation switch for each of the five Purge and Exhaust Isolation valves, "1/valve" is added in each of the three columns. This change clarifies that there is not a single actuation switch only for the Purge and Exhaust Isolation valves which when actuated manually will isolate all five valves.
Each valve maintains a single actuation switch. This change is strictly administrative and does not affect the plant accident analyses or safety margins.
-3 Existing Technical Specifications Refer to Attachment 1 Proposed Technical Specifications Refer to Attachment 2 Safety Evaluation Proposed Change No. 174 is determined not to constitute a significant hazards consideration based on the following review questions and responses.
- 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
This proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Overall the proposed change provides clarification and relief within the technical specifications for plant operations. This proposed change does the following:
- a. The provisions of 3.0.4 are not applicable to the Action Statement for the Containment Radioactivity-High instrumentation being inoperable. The Action Statement requires the purge and exhaust valves to be isolated during operations which is the normal configuration for these valves during operations. The condition of the plant remains the same and the probability or consequences of accidents are not changed. Therefore, removing the 3.0.4 applicability does not change the accident probability or consequences but allows the plant to continue into an operational mode.
- b. The grab sample collection and analysis period for the Turbine Building Sump and Yard Sump effluents is changed from 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for both collection and analysis to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for collection and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the subsequent analysis. This change provides relief from performing the analysis within an unreasonably stringent time frame and has no affect on the probability or consequences of an accident. There are no potential sources of highly radioactive effluents which enter these sumps. The collection and analysis of grab samples from this pathway are primarily for documentation purposes. In the event of an accident which may result in radioactive liquid entering these sumps other means of detection would have occurred prior to the liquid entering the sumps.
-4
- c. The radiation monitors which can be utilized for the Sampler Flow Rate Measuring Device within the plant vent stack monitoring system are specifically identified consistent with the other items on Table 3.5.9.1.
This change provides a clarification and has no affect on the accident probability or consequences.
- d. The particular flow element in use in the liquid radwaste effluent line will be channel checked daily. This prevents checking both the element in use and the element not in use which would provide inaccurate information. This change is an operational clarification and has no affect on accident probability or consequences.
- e. The notation indicating a specific radiation monitor does not perform an isolation function and does not have a control room alarm is deleted. The monitor does maintain these functions.
This demonstrates an improvement in the monitor operation and has no affect on the accident probability or consequences.
- f. Removing monitor R-1214 from the technical specifications has no affect on the probability or consequences of an accident.
The function performed by R-1214 will still be provided by other monitors which are in the technical specifications.
Based on the above items discussed, it is clear that this change does not involve 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?
Response
The intent of this proposed change is to provide ease in the daily operations of the plant. The change does not create the possibility of a new or different kind of accident. The change provides:
- a. Clarification by:
- 1. listing those monitors which can be used for the Sampler Flow Rate Measuring Device,
- 2. providing for a channel check of a single flow element which is in use,
- 3. deleting a note which identifies the limitations of a radiation monitor, and
- 4. removing a monitor which is difficult to maintain and calibrate.
-5 These changes have no impact on the plant such that new or different accidents are created. The changes provide clarification to the technical specifications for a more accurate description and use of the plant equipment.
- b. Relief by removing the 3.0.4 applicability on an Action Statement for a containment radiation monitor and increasing the time allowed to perform analyses of certain grab samples.
Increasing the time to perform analysis of grab samples from the Turbine Building Sump or the Yard Sump has no affect on the plant configuration. Therefore, in both cases the plant has not been affected such that a new or different kind of accident has been created.
Based on the above, it is clear that operation of the facility in accordance with the proposed change does not create the possibility of a new or different kind of accident.
- 3. Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?
Response
The changes, as discussed, provide clarification within the technical specifications to improve the plant operation. The changes also provide relief in operations and radwaste sampling areas. These changes facilitate and clarify plant operations.
The allowance of a longer grab sample analysis period is reasonable in that the subject pathway exhibits insignificant activity levels which do not necessitate analysis results within a short time frame. Removing monitor R1214 from the T.S. is reasonable since there are other T.S. monitors which perform the designated function. Therefore, operation of the facility in accordance with this proposed change does not involve a significant reduction in a margin of safety.
Safety and Significant Hazards 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,
- 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.
ACL:8038F:0203U ACL:8039F:2004U