ML13331B076

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Forwards Application for Amend to License DPR-13,consisting of Proposed Change 198 to Tech Specs,Incorporating Requirement to Have RCS Overpressure Protection Sys Operable When RHR Sys in Operation,Per SEP Topic V-11.B.Fee Paid
ML13331B076
Person / Time
Site: San Onofre 
Issue date: 10/27/1988
From: Baskin K
Southern California Edison Co
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML13331B078 List:
References
TASK-05-02, TASK-5-2, TASK-RR NUDOCS 8811030471
Download: ML13331B076 (9)


Text

Southern California Edison Company P.O BOX 800 2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 KENNETH P. BASKIN TELEPHONE EPRPSIN October 27, 1988 88-302-40 U. S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, D.C. 20555 Gentlemen:

Subject:

Docket No. 50-206 Amendment Application No. 154 San Onofre Nuclear Generating Station Unit 1 Enclosed is Amendment Application No. 154 to the Provisional Operating License DPR-13. Amendment Application No. 154 consists of Proposed Change No. 198, which is a request to revise Appendix A, Technical Specifications, of Provisional Operating License DPR-13.

Proposed Change No. 198 is a request to revise Appendix A Technical Specifications to incorporate a requirement to have reactor coolant system overpressure protection systems operable whenever the residual heat removal system is in operation. This change is submitted in conjunction with the resolution to SEP Topic V-11.B, Residual Heat Removal System Interlock Requirements.

Pursuant to 10 CFR 170.12, the review of Proposed Change No. 198 contained in Amendment Application No. has been determined to require a fee of $150.00.

Accordingly, SCE's check in the amount of $150.00 is enclosed.

Very truly yours, Enclosures cc: 3. B. Martin, Regional Administrator, NRC Region V F. R. Huey, NRC Senior Resident Inspector, San Onofre Units 1, 2 and 3 J. 0. Ward, California Department of Health Services 8:I1030 4 7 1O Av P

DC

BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA EDISON

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COMPANY and SAN DIEGO GAS & ELECTRIC COMPANY )

for a Class 104(b) License to Acquire,

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DOCKET NO. 50-206 Possess, and Use a Utilization Facility as

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Part of Unit No. 1 of the San Onofre Nuclear )

Amendment No. 154 Generating Station

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SOUTHERN CALIFORNIA EDISON COMPANY and SAN DIEGO GAS & ELECTRIC COMPANY, pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 154.

This amendment consists of Proposed Change No. 198 to Provisional Operating License No. DPR-13. Proposed Change No. 198 modifies the Technical Specifications incorporated in Provisional Operating License No. DPR-13 as Appendix A.

Proposed Change No. 198 is a request to revise Appendix A Technical Specifications to incorporate a requirement to have reactor coolant system overpressure protection systems operable whenever the residual heat removal system is in operation.

In the event of conflict, the information in Amendment Application No. 154 supersedes the information previously submitted.

-2 Based on the significant hazards analysis provided in the Description of Proposed Change and Significant Hazards Analysis of Proposed Change No. 198, it is concluded that (1) the proposed change does not involve a significant hazards consideration as defined in 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.

Pursuant to 10 CFR 170.12, the fee of $150 is herewith remitted.

-3 Subscribed on this d a y o f 1988.

Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY KB nneth P. Baskin Vice President Subscribed and sworn to before me this a7m day of OFFICIAL SEAL C. SALLY SEBO Notary Public-California

.___LOS ANGELES COUNTY Notary Public in for the County of My Comm. Exp. Apr. 20,1990 Los Angeles, State of California Charles R. Kocher James A. Beoletto Attorneys for Southern California Edison Company By:

JamA Beoletto

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of SOUTHERN

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CALIFORNIA EDISON COMPANY

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and SAN DIEGO GAS & ELECTRIC

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Docket No. 50-206 COMPANY (San Onofre Nuclear

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Generating Station Unit No. 1

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CERTIFICATE OF SERVICE I hereby certify that a copy of Amendment Application No. 154 was served on the following by deposit in the United States Mail, postage prepaid, on the 27th day of October, 1988.

Benjamin H. Vogler, Esq.

Staff Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 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 C. 3. Craig Manager U. S. Nuclear Projects I ESSD Westinghouse Electric Corporation Post Office Box 355 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 ms A. Aeoletto-

DESCRIPTION AND SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS OF PROPOSED CHANGE NO. 198 TO THE TECHNICAL SPECIFICATIONS PROVISIONAL OPERATING LICENSE NO. DPR-13 This is a request to revise Section 3.20, "OVERPRESSURE PROTECTION SYSTEMS" of the Appendix A Technical Specifications for San Onofre Nuclear Generating Station, Unit 1 (SONGS 1).

DESCRIPTION OF CHANGES The following is a summary discussion of the proposed changes to the above discussed technical specification section. The existing specification is provided as Attachment 1 and changes discussed here are provided as.

The NRC review of SEP Topic V-11.B, Residual Heat Removal System Interlock Requirements, as documented in NUREG-0829, "Integrated Plant Safety Assessment, San Onofre Unit 1, Final Report, December 1986," concluded that a requirement to have overpressure protection systems operable, whenever the residual heat removal (RHR) system was in operation, is necessary. Currently, the overpressure protection system limiting condition for operation (LCO) is described in SONGS 1 Technical Specification Section 3.20, "OVERPRESSURE PROTECTION SYSTEMS."

Proposed Change No. 198 will revise 3.20 to require that the overpressure protection system be operable when the RHR system is in operation.

EXISTING TECHNICAL SPECIFICATIONS See Attachment 1 PROPOSED TECHNICAL SPECIFICATIONS See Attachment 2 SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS As required by 10 CFR 50.91(a)(1), this analysis is provided to demonstrate that a proposed license amendment to revise the LCOs for the overpressure protection systems for SONGS 1 represents a no significant hazards consideration. In accordance with the three factor test of 10 CFR 50.92(c),

implementation of the proposed amendment was analyzed and found not to:

1) involve a significant increase in the probability or consequences for an accident previously evaluated; or 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or
3) involve a significant reduction in a margin of safety.

-2 The RHR system has a design pressure of 500 psig. Requiring the overpressure protection systems to be operable during RHR system operation will assure that the design pressure of the RHR system is not exceeded. Maintenance of the RHR boundary is essential to assurance of continued, reliable RHR system operation and, consequently, safety of the reactor core which is cooled by the RHR system.

Analysis Conformance of the proposed amendments to the standards for a determination of no significant hazard as defined in 10 CFR 50.92 (three factor test) is shown in the following:

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 The use of the overpressure protection systems to protect the RHR system do not affect accident probabilities, as the overpressure event occurs by some mechanism external to either of these systems.

However, the overpressure protection of the RHR system is important to provide assurance that, in the event of an overpressurization incident, the RHR system will not be damaged. The continued operation of the RHR system is necessary to maintain the reactor core in a cooled, shutdown configuration. Therefore, it is concluded that operation of the facility in accordance with this 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 this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

RESPONSE: NO The revisions proposed herein require that an existing system, the overpressure protection system, be operable when the RHR system is in operation. Both the RHR system and the overpressure protection system are designed to be operated in this configuration.

Therefore, it is concluded that operation of the facility in accordance with this proposed change does 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?

-3 RESPONSE: NO The revisions proposed herein assure continued compliance with a previously reviewed margin of safety. The NRC concluded, in their review of an SEP Topic associated with the RHR system, overpressure protection for the RHR system is necessary to assure the design margin of safety for the RHR system. 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.

SAFETY AND SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION Based on the preceding analysis, it is concluded that:

(1) Proposed Change No. 198 does not involve 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. - Existing Specification - Proposed Specification LAB:0336n