ML20043H242
ML20043H242 | |
Person / Time | |
---|---|
Site: | Rancho Seco |
Issue date: | 06/19/1990 |
From: | Reynolds S Office of Nuclear Reactor Regulation |
To: | Keuter D SACRAMENTO MUNICIPAL UTILITY DISTRICT |
References | |
TAC-66453, NUDOCS 9006220293 | |
Download: ML20043H242 (13) | |
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Jar June 19,-1990 q
Docket' No.: 50i312 DISTRIBUTION l
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NRC & Local PDRs-PD5 Reading DCrutchfield-i GHolahan DFoster Mr. Dan R. Keuter:
Saeynolds OGC
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Assistant General Manager, Nuclear ACRS'(10)
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Rancho Seco Nuclear Generating Station 114440 Twin Cities Rpad Herald,' California' 95638-9799 m
Dear Mr. Keuter:
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SUBJECT:
' RETURN OF RANCHO SECO'S PROPOSED AMENDMENT 162 (TAC NO. 66453)
We hee suspended our review and are returning the following application for proposed amendment (PA) to Operating License DPR-50 for Rancho Seco:
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PA 162: Waste Gas Concentration Limits.
The continuation of our review of this PA would nrc result in a'significant' increasc in safety nor provide any significani, benefits to SMUD due to the v
following reasons:
1)thepermanentplantclosureonJune 7,1989,2)the P,
defueled state of Rancho Seco, 3) the active pursuit of decommissioning by the
' Sacramento Municipal Utility District (SMUD), and 4) the ongoing review of your application for PA 182:. Defueled Technical Specifications. Therefore, we; are returning your application _(enclosed).
You may resubmit this application for proposed amendment if'the decision to decomaission Rancho Seco is changed.
t Sincerely, F
/s/
o-Steven A. Reynolds, Project Manager
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Project Directorate V i
Division of. Reactor Projects -~III, 4
-IV, V and Special Projects Office of Nuclear Reactor Regulation 1
Enclosure:
"As stated; s
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ATTACHMENT III PAGE 1 0F 1
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NO SIGNIFICANT HAZARDS CONSIDERATION a.
Proposed Amendment No.162 modifies the technical specifications on oxygen and hydrogen concentrations in the Haste Gas Holdup System to provide for periods'in which the system is drained, purged, isolated and in an out-of-service condition, and/or open to the atmosphere. Additionally.
.the r. airs,' Haste Gas Holdup System, is capitalized wherever presently uncapitalized..This latter change is proposed to make the system's name consistent throughout the specifications.
Presently, the technical specifications require that the concentration of oxygen in the Haste Gas Holdup System be limited to not more than four percent.
This limitation ensures that the concentration of potentially explosive gas mixtures contained in the Haste Gas Holdup System is below the flammability limits of oxygen and hydrogen.
However, the existing specifications do not provide for when the Haste Gas Holdup System is l
free of potentially explosive gas mixtures as, for example, when the I
l system is open to the atmosphere for maintenance.
The proposed changes to the technical specification provide for such non-operational conditions, and make the system name consistent throughout the applicable specifications.
l-The District has reviewed the proposed changes against each of the i
criterion of 10'CFR 50.92 and concluded that the changes to the Technical-l Specifications to provide for the non-operational-conditions discussed l
above would not:
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involve a significant increase in the probability or consequences of j
L an accident previously evaluated because the proposed changes simply provide for.the non-operational conditions during which a potentially explosive gas mixture in the Haste Gas Holdup System is precluded, or l
b, create the possibility of a new or different kind of accident from
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any previously analyzed because the proposed changes simply provide l
for the non-operational condition during which the Haste Gas Holdup l
System is free of any potentially explosive gas mixtures.
There are L
no changes to the design or operation of the plant, thus no i
i possibility of a different of new kind of accident is introduced.
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Or involve a significant reduction in a margin of safety because no design or operational changes are proposed.
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~ The' proposed capitalizing of the system name, Haste Gas Holdup System, is i
purely administrative, and thus has no involvement with any accident' L
concerns or margins of safety.
On the basis of the above, the District concludes that the proposed changes do not constitute any significant hazards to the public, and in no v;y endanger the public's health and safety.
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7-ATTACHMENT II (Cont.)
FACILITY CHANGE SAFETY ANALYSIS PAGE 4 0F 4
. PROPOSED AMENDMENT NO.162. REY. O Summary (Cont.)
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The Technical Specification changes included it the Proposed Amendment do not circumvent the requirements to maintain a non-flamable atmosphere in the Waste Gas Holdup System. The changes do reflect the fact that a flammable mixture of hydrogen and oxygen is precluded when the system is drained.
purged, and isolated, j
Proposed Amendment No.162 does not change the facility as described in the USAR. The changes do not affect the function of the Waste Gas Holdup System, nor do they affect the safety function or any safety system. No failure modes are introduced by the changes since the requirements are changed only when the H
system has been removed from service, isolated, drained, or purged. The
,.N changes:do not involve " Major Changes to Radioactive Waste Treatment Systems" l
hl as defined in Technical Specification Section 6.17.3;B.
I The probability of occurrence or the consequences of'an accident or I
malfunction of equipment important to safety previously evaluated in the safety analysis report will not be increased since the changes only affect the T
Waste-Gas Holdup System once,the syttem us been removed from service and isolated' from any source of hydroge i gas.
The possibility for an accident of malfunction of a different type than any evaluated previously in the safety analysis report will not be created since q
any explosive concentrations of hydrogen gas are purged from the system and sources of hydrogen are isolated prior to the system being taken out-of-service and opened to the atmosphere.
J" The margin of safety, as defined in the basis for any Technical S>ecification, is not reduced since the possibility of the formation of a flama>1e mixture of hydrogen and~ oxygen is precluded by the proposed amendment; present-Technical Specification Bases are met.
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. Therefore, Proposed Amendment No.162 does not involve an Unreviewed Safety l
Question.
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ATTACHMENT II (Cont.)
FACILITY CHANGE-SAFETY ANALYSIS PAGE 3 0F 4 PROPOSED AMENDMENT NO. 162, REY. 0 Effects on Safety Functions (Cont.)
Therefore, adaptation of Proposed Amendment No.162 will not affect the functioli of the Waste Gas Holdup System or the safety function of any safety system.
Analysis of Effects on Safety Functions This proposed revision to Technical Specification Sections 3.24 and 4.28 is part of the corrective action for Licensee Event Report 87-018, dated March M, 837 (attached). This LER was generated because of the failure to
- continwib monitor the oxygen concentration in the Waste Gas Holdup System when the s hem was out-of-service. The system had been taken out-of-service c
for planned maintenance and had been sampled, drained, purged,and opened to atmosphere.
The present Technical Specification Section 3.24 does not provide for those times when the system is isolated for maintenance and may be open to atmosphere. During these periods, it is not possible to maintain oxygen levels below 4%.
Proposed Amendment No.162 allows oxygen levels in the system to exceed 4%, but only when all sources of hydrogen are eliminated and existing hydrogen concentrations are reduced to (or are deterinined to be) less than or equal to 4%.
Proposed Amendment No.162 does not require sampling of the Waste Gas Holdup System during cold shutdown when the system has been drained, ) urged, isolated, and in an out-of-service condition. This reflects tie fact that the creation of a flammable mixture of oxygen and hydrogen is not operationally possible when the Waste Gas Holdup System is drained, purged, and isolated.
The changes to Technical Specifications in Proposed Amendment No.162 meet the Bases of the present Technical Specification Section 3.24
"...to ensure that the concentration of potentially explosive gas mixtures contained in the waste gas treatment system is maintained below the flammability limits of hydrogen and oxygen."
Sunnary Proposed Amendment No.162 to Rancho Seco Technical Specifications modifies Technical Specification Section 3.24, Explosive Gas Mixture and its associated Surveillance Standard, Section 4.28.
In Section 3.24. the Proposed Amendment changes the Action Statement and includes a paragrapti which modifies the applicability of the requirements when the Waste Gas Holdup System is drained, isolated, and out-of-service.
A paragraph is also added to the Surveillance Requirements which modifies Section 4.28 in the same manner, i
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ATTACHMENT II (Cont.)
FACILITY CHANGE SAFETY ANALYSIS PAGE 2 0F 4-PROPOSED AMENDMENT NO.162, REY. O Safety Functions of Affected Systems / Components Equipment and piping of the Waste Gas Holdup System are all housed within l
seismic Class I structures. The Waste Gas Holdup System is not a safety-related system. All major components of the system that could present a radiation hazard to plant personnel are contained within rooms that are separated by concrete walls (USAR Section 11.1.3, Radioactive Gas Waste Disposal System).
The Waste Gas Holdup System safely collects, stores, and disposes of gases that evolve from primary coolant in all tanks or other equipment where this might occur.
The Weste Gas Holdup System is divided into two subsystems, one '
to handle high activity waste gases and the other to handle low activity gases (USAR Section 11.3.1, System Function).
Gas streams containing primarily hydrogen gas are processed separately from streams containing air gas. Those systems containing hydrogen gas are directed to the Waste Gas Surge Tank.
(USAR Section 11.1.3.1.3, Hydrogen Gas Mixtures)
Effects on Safety Functions The objective of monitoring the oxygen concentration in the Waste Gas Holdup System is to ensure that the concentration of potentially explosive gas mixtures contained in the Waste Gas Holdup System is maintained below the
' flammability limits of hydrogen and oxygen to prevent an explosion. This also I
helps ensure the integrity of the Waste Gas Holdup System and that the release of radioactive materials will be controlled in conformance with the requirements of General Design Criterion 60 of 10 CFR 50, Appendix A.
The lower limit of flammability for hydrogen'and for oxygen is approximately 5% by volume (Bureau of Mines, Bulletin 503).
If the concentration of either gas is kept below this limit, the other gas may be present in higher amounts without danger of producing an explosive mixture.
The proposed amendment requires /the oxygen concentration of the Waste Gas Holdup System to be less than or equal to 4% unless all sources of hydrogen have been eliminated, and any existing hydrogen reduced to less than a 4% concentration. 'This allows for opening-the system to atmos)here, (after. draining, purging, and isolating the system) which would cause t1e oxygen concentration to be greater than 4%.
A District letter to the'NRC, dated March 11, 1982, contained an attachment which explained the District's use of a 4% oxygen concentration limit, instead of the 2% limit specified in the standard Radiological Effluent Technical Specifications. The letter and the appropriate section of the attachment are included in this safety analysis.
Additionally, the relaxation of the oxygen sampling requirements in Section 4.28 is-only allowed when the system is drained, purged, isolated, and in an out-of-service condition.
ATTACHMENT II FACILITY CHANGE SAFETY ANALYSIS PAGE 1 0F 4 PROPOSED AMENDMENT NO.162, REY. O DESCRIPTION:
Proposed Amendment No.162 modifies Technical Specification Section 3.24, Explosive Gas Mixture, and its associated Surveillance Standard, Section 4.25.
In Section 3.24, the Proposed Amendment adds an exception to the oxygen-limit applicability and changes the format of the Action Statement and includes the sentence "When any part of the Waste Gas System is to be removed from service and/or opened to atmosphere, first ensure that the hydrogen-concentration is <4% and that all sources of hydrogen have been eliminated.
The oxygen concentration limit is not applicable when the system is drained, purged, isolated and in an out-of-service condition." Additionally, the following paragraph is added to the Bases:
"The requirements of this specification are not violated when the Waste Gas Holdup System is drained, purged, isolated, and in an out-of-service condi tion. "
The following paragraph is added to the Surveillance Requirements of Section 4.28:
" Sampling during cold shutdown shall not be required when the Waste Gas' Holdup System is drained, purged, isolated, and in an out-of-service condition."
REASON FOR CHANGE:
Purpose The present Applicability statement of Technical Specification 3.24, Explosive Gas Mixture, requires the concentration of oxygen in the Waste Gas Holdup System to be less than-or equal to-4% at all times, and if exceeded, the concentration of oxygen is to be reduced to'less than or equal to 4% within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
Section 4.28 requires continuous monitoring of the waste gases in the Waste Gas Holdup System. These requirements are not practical or relevant for the conditions when the Waste Gas Holdup System has been drained, purged, isolated, is in an~ out-of-service condition, or is open to atmosphere.
This proposed amendment clarifies the requirements for operability and sampling of the Waste Gas Holdup System to allow for maintenance or other periods when the system is drained, purged, isolated, and in an out-of-service condition.
EVALUATION AND. BASIS FOR SAFETY FINDINGS:
Systems, Subsystems, Components Affected Proposed Amendment No.162 affects the Waste Gas Holdup System.
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RANCHO SECO UNIT 1 4
TECHNICAL SPECIFICATIONS 4
Limiting Conditions for Operation 4.28 EXPLOSIVE GAS MIXTURE Surveillance Reauirements 1624+
The concentration of oxygen in the Waste Gas Holdup System shall be determined to be within the limits specified in 3.24 by continuously 1624+
monitoring the waste gases in the Waste Gas Hold-up System with the oxygen monitor demonstrated OPERABLE according to Table 4.28-1.
If the continuous monitor is inoperable, a daily sample will be taken and analyzed; during heatup or cooldown, a sample will be taken and analyzed within four hours.
162*
Sampling shall not be required when the Waste Gas Holdup System is drained, purged,. isolated, and in an out-of-service condition.
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Bases This specification is provided to ensure that the concentration of 1624 potentially explosive gas mixtures contained in the Waste Gas Treatment System is maintained below the flammability limits of hydrogen and oxygen.
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1 Maintaining the concentration of oxygen below the flammability limit provides assurance that the releases of radioactive materials will be controlled in conformance with the requirements of General Design Criterion i
l 60 of Appendix A and 10 CFR Part 50.
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Proposed Amendment No.162 4-87
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RANCHO SECO UNIT 1 TECHNICAL SPECIFICATIONS Limiting Conditions for Operation 3.24 EXPLOSIVE GAS MIXTURE 1624 The concentration of oxygen in the Waste Gas Holdup System shall be limited to 5 4% by volume, except when the system is drained, purged, isolated and in an out-of-service condition.
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Applicability At all times Action 162*
A.
With-the concentration of oxygen in the Waste Gas Holdup System >4%
by volume, immediately suspend all additions of waste' gases to the system, and reduce the oxygen concentration to $4% within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
'1624 B.
When any.part of the Waste Gas System is to be removed from service and/or opened to the atmosphere, first ensure that the hydrogen concentration is 5 4% and that all sources of hydrogen have been-eliminated. The oxygen concentration limit is not applicable when j
the system is drained, purged, isolated and in an out-of-service
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condition.
Bases This specification is provided to ensure-that the concentration of i
162*
potentially explosive gas mixtures contained in the Waste Gas Treatment System is maintained below the flammability limits of hydrogen and oxygen.
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Maintaining.the concentration of oxygen below the flammability limit provides assurance that the releases of radioactive materials will be controlled in conformance with the requirements of General' Design Criterion 60 of Appendix-A and 10 CFR Part 50.
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-The requirements of this specification are not violated when the Waste Gas Holdup System is drained, purged, isolated, and in an out-of-service
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condition.
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Proposed Amendment No. 162 3-89 m
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l Director, Nuclear Tech. Services MS 206A Director, Nuclear Ops. & M6 int.
MS'257 Director, Plant Support MS 258 Director, Sys. Rev. & Test irgm. MS 259 L
Modifications Manager MS 201 1
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Manager, Nuclear Licensing MS 286 X
Manager, Nuclear Engineering MS 208-6 4
Manager, Cost Control Services MS 270 Public Information MS 204 Manager Maintenance MS 254
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170.21,." Schedule of Fees."
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The District' intends to implement this proposed amendment immediately.
after the NRC's approval and issuance.
.If there are any questions concerning this report, please contact-
-Mr. Ron H. Colombo at (916) 452-3211, extension 4236.
Sincerely, o
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. Carl Andognini
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Chief Executive Officer, Nuclear Sworn to and subscribed before me this MM day of Septenber,1987.
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A. D'Angelo. NRC Rancho Seco J. B. Hartin (2)
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SACRAMENTO MUNICIPAL UTIUTY DISTRICT ~ P. O. Box 15830 Sectemento CA 95852183ol(916) 452 3211 AN ELECTRIC SYSTEM SERVING THE HEAPT OF CALIFORNIA
.SEP 2 1 1987
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g Docket No. 50-312 Rancho-Seco' Nuclear Generating Station Unit # 1 License No.,DPR ' PROPOSED AMENDMENT No. 162
Dear Mr. Miraglia:
In accordance with 10 CFR 50.90, the Sacramento Municipal Utility District proposes to amend its Operating License DPR-54 for Rancho Seco, and herewith submits Proposed Amendment No. 162 for this purpose.;
Presently,.the technical specifications require that the concentration of oxygen in the Haste Gas Holdup System be limited to not more than-four percent by volume.
This limitation ensures that the concentration of.
potentially explosive gas mixtures contained in the Haste Gas Holdup System is below the flammability limits of hydrogen and oxygen.
However,.
the existing specifications do not provide for when the Haste Gas Holdup-System is free of potentially explosive gases,.as for example, when the system is isolated and open'to the atmosphere for maintenance.
(This is
.a condition during which the oxygen concentration'is much greater.than four percent; but the hydrogen concentration ~is much less than four percent.)- The revised pages of the Rancho Seco Technical Specifications presented as Attachment I provide for such conditions.
Details of Proposed Amendment No. 162 are presented in this submittal as the Description, Reasons for Change, and Evaluation and Basis for Safety Findings as Attachment II. and No Significant Hazards Consideration as Attachment III.
Pursuant to 10 CFR 50.91(b)(1), the Radiological Health Branch of the California State Department of Health Services has been informed of this proposed amendment by mailed copy of this submittal.
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e RANCHO SECO NUCLEAR GENERATING STATION : 1444o Twin Cities Road, Herald, CA 95638 9799;(209)333 2935
n Mr. Dan R. Keuter Rancho Seco Nuclear Generating.
Station
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Mr. David Boggs, General Manager Mr. John Bartus Sacramento Municipal. Utility District Ms. JoAnne Scott 6201 S Street.
Federal Energy Regulatory Consnission P.O. Box.15830-825 North Capitol Street, N. E.
Sacramento, California.95813 Washington, D.C.
20425 Thomas A~ Bcxter, Esq.
Ms. Helen Hubbard Shaw, Pittman, Potts & Trowbridge P. O. Box 63 2300 N Street, N.W.
Sunol, California 94586 Washington, D.C.
20037 Environmental Conservation Mr. Steven Crunk Organization Manager, Nuclear Licensing Suite 320 Sacramento Municipal Utility District 101 First Street Rancho Seco Nuclear Generating Station Los-Altos, California 94022 14440. Twin Cities Road Herald, California 95638-9799 Ms. Jan Schori, General Counsel Sacramento Municipal Utility District Mr. Robert B. Borsum, Licensing 6201 S Street-Representative P.O. Box 15830
. Babcock & Wilcox Sacramento, California 95813 LNuclear Power Division 1700 Rockville Pike - Suite 525 Rockville, Maryland 20852
-Resident' Inspector / Rancho Seco c/o"U.- S..N. R. C.
14440 Twin Cities Road m
Herald, California 95638 Regional Administrator, Region V U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 Mr. John Hickman Senior' Health Physicist Environmental Radioactive Management Unit Environmental Management Branch State Department of Health Services
.714 P' Street, Room 616 Sacramento, California 95814 Sacramento County Board of_ Supervisors
'700 H Street, Suite 2450 Sacramento, California 95814
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WASHINGTON, D. C. 20555 June 19, 1990 k.....,/
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Docket No. 50-312 Mr. Dan.R. Keuter:
Assistant General Manager, Nuclear 1
Rancho Seco Nuclear Generating Station j
14440-Twin Cities Road Herald,- California 95638-9799 q
Dear Mr. Keuter
SUBJECT:
RETURNOFRANCHOSECO'SPROPOSEDAMENDMENT162(TACNO.66453)-
E We have suspended our review and are returning the following application for proposed amendment (PA) to Operating License DPR-54 for Rancho Seco:
1.
PA 162: Waste Gas Concentration Limits.
The continuation of our review of this PA would not result in a significant increase in safety.nor provide any significant benefits to SMUD due to the following reasons:
- 1) the permanent plant closure on June 7,1989,2)the
- defueled state of Rancho Seco, 3) the active pursuit of decommissioning by the Sacramento Municipal Utility District (SMUD), and 4) the ongoing review of your. application for PA 182: Defueled Technical Specifications. Therefore, we are returning your application (enclosed).
You.may resubmit this application for proposed amendment if the decision to
' decommission Rancho Seco is changed, i
Sincerely, s
Steven A. Reynolds, Project Manager Project Directorate V Division of Reactor Projects - III, IV, Y and Special Projects Office of Nuclear Reactor Regulation
Enclosure:
As stated cc w/o. enclosure:
See next.page
.