ML20059F312

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Amend Applications 135 & 119 to Licenses NPF-10 & NPF-15, Respectively,Consisting of Proposed Change Number (PCN) PCN-430,revising Operability Requirements of Containment Isolation Valves in TS Table 3.6-1,Section D
ML20059F312
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 11/03/1993
From: Rosenblum R
SOUTHERN CALIFORNIA EDISON CO.
To:
Shared Package
ML20059F306 List:
References
NUDOCS 9311040234
Download: ML20059F312 (11)
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i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA ) Docket No. 50-361 EDISON COMPANY, ET AL. for a Class 103 )

License to Acquire, Possess, and Use )

a Utilization Facility as Part of ) Amendment Application  :

Unit No. 2 of the San Onofre Nuclear ) No. 135 Generating Station )

SOUTHERN CALIFORNIA EDIS0N COMPANY, ET AL. pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 135.

This amendment application consists of Proposed Change Number (PCN)-430 to Facility Operating License No. NPF-10. PCN-430 is a request to revise Unit 2 Technical Specification 3/4.6.3, " Containment Isolation Valves," to require valves listed in Section D of existing Table 3.6-1, " Containment Isolation valves," to be in an Action statement when secured in their Engineered Safety Feature Actuation System (ESFAS) actuated position. The existing TS considers these valves to be operable although they may be unable to perform their containment isolation function. The Bases 3/4.6.3 is also revised.

9311040234 931103 E PDR ADOCK 05000361

, Subscribed on this 8Ab day of MOVE /H 6E/L ,1993.

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Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY

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By:

R. M. Rosenblum Vice President State of California JY3/9 3 before me,]AA'8MA b. lYWWY US personbily appeared 'Mc /Mr2 /1, Restort.g m , personally known to me to be the person whose name is subscribed to the within instrument and acknowledged to me that he executed the same in his authorized capacity, and that by his signature on the instrument the person, or the entity upon behalf of which the person acted, executed the instrument.

WITNESS my hand and official seal.

Signature h /Y h N .

IM" g____--- --

OFFICIAL SEAL f

Nohw Putsc-Collfornio ,

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@ BAR!AllA A CRANGE COUNTY her Centenden Iss*es M 31,1996

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J UNITED STATES OF AMERICA '

NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA Docket No. 50-362

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EDISON COMPANY, ET AL. for a Class 103 )

License to Acquire, Possess, and Use )

a Utilization Facility as Part of ) Amendment Application Unit No. 3 of the San Onofre Nuclear ) No. 119 Generating Station ) .

SOUTHERN CALIFORNIA EDISON COMPANY, ET AL. pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 119.

This amendment application consists of Proposed Change Number (PCN)-430 to Facility Operating License No. NPF-15. PCN-430 is a request to revise Unit 3 l l

Technical Specification 3/4.6.3, " Containment Isolation Valves," to require  :

valves listed in Section D of existing Table 3.6-1, " Containment Isolation Valves," to be in an Action statement when secured in their Engineered Safety Feature Actuation System (ESFAS) actuated position. The existing TS considers these valves to be operable although they may be unable to perform their l containment isolation function. The Bases 3/4.6.3 is also revised.

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Subscribed on this 84b day of /JOVEM 66 & 1993.

Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY

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I By: /, , er ,

m R. M. Rosenbl6m l Vice President  ;

l State of California l l l3/9 before me, $$pAAAA A H'<'arryvluc78tY W l persorfalTy appeared '8/r AIMb H. T(eSe A/6Ltr M , pet sonally known to I me to be the person whose name is subscribed to the within instrument and j acknowledged to me that he executed the same in his authorized capacity, i and that by his signature on the instrument the person, or the entity upon i behalf of which the person acted, executed the instrument.

WITNESS my hand and official seal. l 1

Signature b /~c A o O . t OFFICIAL SEAL

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C M4/ sem uC Cmu Notory Putsc-CONornio ORANGE COUNTY l

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I Mr Commlulon Epos Mesch 31,1995 I

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NPF-10/15-430 i i

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ENCLOSURE 1 i i

PCN-430 l

PROPOSED CHANGES TO TECHNICAL SPECIFICATION 3/A.6.3 l AND BASES 3/4.6.3 l

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DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-10/15-430 l

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This is a request to revise Technical Specification (TS) 3/4.6.3, " Containment _ l l

Isolation Valves," to require valves listed in Section D of existing Table 3.6-1, " Containment Isolation Valves," to be in an Action statement when j secured in their Engineered Safety Feature Actuation System (ESFAS) actuated i position. The associated Bases 3/4.6.3, " Containment Isolation Valves," is i also revised.

Existino Specifications i

l Attachment A - Existing Specifications, Unit 2  :

Attachment B - Existing Specifications, Unit 3 Proposed Specifications l

6 Attachment C - Proposed Specifications, Unit 2 l Attachment D - Proposed Specifications, Unit 3 l.

DESCRIPTION The proposed change revises TS 3/4.6.3, " Containment Isolation Valves," and its associated Bases to require the valves listed in Section D of Table 3.6-1 to be in an Action statement when secured in their Engineered Safety Feature  :

Actuation Signal (ESFAS) actuated position. By the footnote "***" in the existing TS, these valves are considered OPERABLE even though they may be unable to perform their containment isolation function. The following changes are proposed for TS 3/4.6.3 and its associated Bases.

1. Add "E" in existing Action 1. This change requires the new Section E valves to follow this TS Action if they become inoperable.
2. Relocate Action 1.d, "The provisions of Specification 3.0.4 are not applicable." as Action 4. This change is made to ensure the provisions j of Specification 3.0.4 are not applicable to all the Action statements.
3. Replace existing Action 2 with "With one or more of the valves specified i in Section D1 of Table 3.6-1 inoperable, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> secure the

! inoperable valve (s) in its ESFAS actuated position, and restore the i inoperable valve (s) to OPERABLE status during the next cold shutdown or 30 days, whichever is shorter; otherwise be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 i

hours." This change provides a new Action and Allowed Outage Time (A0T) for proposed Section D1 valves based on the results of specific risk

evaluations for valves that may be secured open. The phrase in existing Action 2 which states "the appropriate ACTION statement (s) of those
Limiting Conditions for Operation pertaining to the valve (s) or system

, in which it is installed shall be applicable" is relocated to the Bases.

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4. Add Action 3 "With one or more of the valves specified in Section D2 of ,

Table 3.6-1 inoperable, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> secure the inoperable valve (s) in i its ESFAS actuated position, and restore the inoperable valve (s) to j OPERABLE status during the next cold shutdown; otherwise be in at least  !

HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the j following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />." This change provides a new Action and A0T for  !

proposed Section D2 valves based on the results of specific risk  !

evaluations for valves that may be secured open. l

5. Relocate Surveillance Requirement (SR) 4.6.3.1 to the next page due to text overflow. This change is editorial.  ;
6. Add "E" to SRs 4.6.3.1 and 4.6.3.2. This change provides the SRs for f the new Section E valves.
7. In SR 4.6.3.5 replace "D" with "D1, and D2," and replace the last sentence " Valves secured ** in the ESFAS actuated position are considered i OPERABLE pursuant to this specification." with " Specification 4.0.5 is not applicable when the valves are secured cpen." This change is due to ,

the new Actions and A0Ts provided for these valves. The stroke test  !

required by this surveillance cannot be performed when the valves are )

secured open. l 1

1 8. Reorganize existing Section D in Table 3.6-1 into Se:tions D1, " Safety l Injection," D2, "Other" and E, "Other." Section D1 includes a number of- 1 High Pressure Safety Injection (HPSI) and Low Pressure Safety Injection  :

(LPSI) valves which may be secured open for a maximum of 30 days. I Section D2 includes other valves which may be secured open until the )

next cold shutdown. The proposed A0Ts for Sections D1 and D2 valves are j based on the results of specific risk evaluations. Section E includes <

check valves, valves with both open and closed ESFAS positions, and valves whose ESFAS position is to close.

9. Delete or relocate footnotes in Table 3.6-1, as appropriate, based on the proposed reorganization of the existing Section D valves.
10. The existing Bases for Section D is revised to reflect the basis for the new Section D1, D2, and E valves.

DISCUSSION

TS 3/4.6.3, " Containment Isolation Valves," 1) requires the valves listed in Sections A, B, C, and D of Table 3.6-1 to be OPERABLE in Modes 1 through 4, 2)- ,

specifies surveillance requirements to verify operability and, 3) provides the  ;

actions to be taken when the operability requirements are not met. The operability of the containment-isolation valves ensures that the containment atmosphere will be isolated from the outside environment in the event of a  ;

postulated accident.

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l The existing Section A, " Automatic Containment Isolation," valves are

! containment isolation valves which are actuated by a Containment Isolation Actuation Signal (CIAS). Section A also includes check valves inside i containment which are considered to be automatic containment isolation valves i in accordance with 10 CFR 50 General Design Criteria. The existing Section B,

" Containment Purge," valves are containment purge isolation valves which are actuated by the Containment Purge Isolation Signal (CPIS). The existing Section C, " Manual," valves are those manual isolation valves which are assumed to be closed post-accident and can be opened intermittently during <

normal operation under administrative control. The existing Section D, I "Other," includes 1) valves whose normal safe post-accident position is open, I

2) check valves, 3) valves whose ESFAS actuated position is closed, and 4) '

valves with dual ESFAS functions (open/close).

The proposed change to TS 3/4.6.3 reorganizes the existing Section D valves into three sections (DI, D2, and E) and provides the appropriate Action and l Allowable Outage Time (A0T) for each section. Specific risk evaluations were  !

performed to assess the appropriate A0Ts for the valves that can be secured ,

open. The conclusion from these evaluations was that many of these valves can be secured in the open position indefinitely. However, for a number of High Pressure Safety Injection (HPSI) and Low Pressure Safety Injection (LPSI) l valves the appropriate A0T is 90 days for the valves to not make a significant l contribution to the risk of a significant offsite release. These valves are  !

proposed as the new Section D1 valves. Although a 90-day A0T has been found I to be acceptable, we are proposing a more conservative 30-day A0T for these l valves. New Section D1 valves will follow proposed Action 2 which states 1 "With one or more of the valves specified in Section D1 of Table 3.6-1 inoperable, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> secure the inoperable valve (s) in its ESFAS actuated position, and restore the inoperable valve (s) to OPERABLE status during the next cold shutdown or 30 days, whichever is shorter; otherwise be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />." These valves are required to be OPERABLE prior to Mode 4 entry from the next cold shutdown or 30 days, whichever is shorter.

I Proposed Section D2 valves were found by specific risk evaluations to not make l

a significant contribution to the risk of a significant offsite release if i these valves are secured open indefinitely. Therefore, they are permitted to l

be in the open position until the next cold shutdown. These new Section D2 valves will follow proposed Action 3 which states "With one or more of the valves specified in Section D2 of Table 3.6-1 inoperable, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> secure the inoperable valve (s) in its ESFAS actuated position, and restore the inoperable valve (s) to OPERABLE status during the next cold shutdown; otherwise be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />." These valves are required to be operable prior to Mode 4 entry from the next cold shutdown.

Proposed Section E valves (check valves, valves with both open and closed ESFAS positions, and valves whose ESFAS position is closed) should not be secured open and should be treated like the existing valves in Sections A, B, and C of Table 3.6-1. These valves will follow existing Action 1 of TS 3.6.3.

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Basis for and Acceptability of the Recuest This change is necessary to require the containment isolation valves in the I existing Section D of Table 3.6-1 to be in an Action statement when secured in their ESFAS actuated position. The existing TSs consider these valves to be operable when secured in their ESFAS actuated position although they may be unable to perform their containment isolation function. The existing TS does .

not provide restrictions on the length of time these valves can be secured and operational mode changes are permitted with the valves not restored to full functionality / operability. Additionally, the footnote which allows these  !

valves to be secured in their ESFAS actuated position is not appropriate for i some Section D valves, i.e., check valves, valves having dual ESFAS positions, I and valves whose ESFAS position is closed.

l This change reorganizes the existing Section D valves in Table 3.6-1 into  ;

three new sections (DI, D2, and E). Each section is provided with new Actions l and A0Ts as appropriate. Section D1 and D2 valves have open ESFAS actuated j positions. Section E valves are check valves, valves with dual ESFAS l positions, and valves whose ESFAS actuated position is closed. The A0Ts for j the Section D1 and D2 valves are based on the results of specific risk '

evaluations which assessed their contribution to core damage frequency and significant offsite release frequency. The Section E valves follow the existing Action 1 of TS 3.6.3.

The specific risk evaluations were based on the following acceptance criteria:

1) the risk of continued operation with the valves secured in their ESFAS actuated position shall be less than the risk of shutdown (core damage risk per shutdown is +5 E-7) and 2) the increase in risk of core damage frequency (CDF) and significant offsite release frequency (SORF) shall be less than 1%

of current Individual Plant Examination (IPE) values (1% of IPE values are

<+3.1E-7 per year for core damage and <+4.9E-8 per year for significant offsite release). The CDF and SORF values in the April 29, 1993 IPE submittal to the NRC have been recently updated, and <+3.1E-7 and <+4.9E-8 per year for CDF and SORF, respectively, are consistent with the updated IPE values.

For the new Section D1 valves 1) the risk of core damage while continuing to operate with the valves secured in their ESFAS actuated position is less than the risk of shutdown and 2) the increase in either core damage frequency or significant offsite release frequency associated with securing these valves in their ESFAS actuated position for 90 days is less than 1% of current IPE values.

For the new Section D2 valves 1) the risk of core damage while continuing to operate with the valves secured in their ESFAS actuated position is less than the risk of shutdown and 2) the increase in either core damage frequency or significant offsite release frequency associated with securing these valves in  ;

their ESFAS actuated position indefinitely or until the next cold shutdown is less than 1% of the updated IPE values.

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r SAFETY ANALYSIS 4 i

The proposed change described above shall be deemed to involve a significan1i hazards consideration if there is a positive finding in any one of the l 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 The proposed change provides new actions and Allowed Outage Times (A0Ts) for valves in Section D of Technical Specification (TS) Table 3.6-1 that  ;

, are currently allowed by the existing TS to be secured for an indefinite [

period of time as long as they are secured in their Engineered Safety Feature Actuation System (ESFAS) actuated position. These valves are  !

considered operable by the existing TS although they may be unable to  ;

perform their containment isolation function. The proposed change i ensures that these valves are returned to operable status within specified times based on the results of specific risk evaluations on <

their contribution to core damage or offsite dose release. The proposed I change does not involve a physical change to the facility as described j in the Updated Final Safety Analysis Report (UFSAR). Therefore, this j q

proposed 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 from any {

accident previously evaluated?

J Response: No The ESFAS actuated positions of these valves are the positions assumed J

in the safety analysis. There are no new accidents associated with this l proposed change because the previously analyzed events already 4

considered failures of containment isolation valves. The plant is equipped with dual and redundant containment iselation valves. Leaving  !

2 the valves in their ESFAS actuated positions does not create a new accident. Therefore, this proposed change does not create the j 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

, This proposed change 1) limits the A0T of certain valves based on contributions to core damage and offsite dose release when the valves are secured in their ESFAS actuated position and 2) requires these valves to be returned to OPERABLE status prior to Mode 4 entry from a cold shutdown to ensure they are available to perform their intended i j

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containment isolation function. Previously, these valves could be secured in the ESFAS actuated position indefinitely. Therefore, this proposed change does not involve a significant reduction in a margin of safety.

Significant Hazards Determination Based on the above 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. Moreover, because this action does not involve a significant hazards consideration, it will also not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.

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