ML20086F026
| ML20086F026 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/06/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20086F022 | List: |
| References | |
| NUDOCS 9507120383 | |
| Download: ML20086F026 (6) | |
Text
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4 UNITED STATES S
NUCLEAR REGULATORY COMMISSION E
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.106 TO FACILITY OPERATING LICENSE NO. DPR-80 AND AMENDMENT NO.
105 TO FACILITY OPERATING LICENSE NO. DPR-82 PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON NUCLEAR POWER PLANT. UNITS 1 AND 2 DOCKET NOS. 50-275 AND 50-323 1.0 INJRODUCTION By letter of February 16, 1994, as supplemented by letter dated April 25, 1995, Pacific Gas and Electric Company (PG&E or the licensee) submitted a request for changes to the Technical Specifications (TS) of the Diablo Canyon Nuclear Power Plant, Units 1 and 2 (DCPP). The proposed amendments would revise TS 3/4.7.2, " Steam Generator Pressure / Temperature Limitation," 3/4.7.7,
" Snubbers," 3/4.7.8, " Sealed Source Contamination," 3/4.7.11, " Area Temperature Monitoring," and 3/4.7.13, " Flood Protection," in accordance with the Commission's final policy statement for relocation of current TS that do not satisfy any of the policy statement criteria.
The April 25, 1995, supplemental letter provided additional clarifying information and did not change the initial no significant hazards consideration determination published in the Federal Reaister on April 13, 1994 (59 FR 17603).
2.0 BACKGROUND
Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plant operating licenses to state TS to be included as part of the license.
The Commission's regulatory requirements related to the content of 15 are set forth in 10 CFR 50.36.
That regulation requires that the TS include items in five specific categories, including (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls.
However, the regulation dces not specify the particular requiraments to be included in a plant's TS.
i The Commission has provided guidance for the contents of TS in its " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reacto s" (" Final Policy Statement"), 58 FR 39132 (July 22,1993), in which the Commission indicated that compliance with the Final Policy Statement satisfies 9182a of the Act.
In particular, the Commission indicated that I
certain items could be relocated from the TS to licensee-controlled documents, consistent with the standard enunciated in Portland General Electric Co.
(Trojan Nuclear Plant), ALAB-531, 9 NRC 263, 273 (1979).
In that case, the j
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_ Atomic Safety and Licensing Appeal Board indicated that " technical specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety."
Consistent with this approach, the Final Policy Statement identified four criteria to be used in determining whether a particular matter is required to be included in the TS, as follows:
(1) installed instrumentation that is used l
to detect, and indicate in the control room, a significant abnormal degrada-tion of the reactor coolant pressure boundary; (2) a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (3) a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a DBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (4) a structure, system,orcomponentwhichoperatingexperienceorprobabilistip safety assessment has showa to be significant to public health and safety.
As a result, existing TS requirements which fall within or satisfy any of the I
criteria in the Final Policy Statement must be retained in the TS, while those TS requirements which do not fall within or satisfy these criteria may be relocated to other, licensee-controlled documents.
3.0 EVALUATION j
i PG&E has proposed to delete TS 3/4.7.2, " Steam Generator Pressure / Temperature 1
Limitation," 3/4.7.7, " Snubbers," 3/4.7.8, " Sealed Source Contamination,"
3/4.7.11, " Area Temperature Monitoring," and 3/4.7.13, " Flood Protection," and move these requirements to the DCPP Equipment Control Guidelines (ECGS). The l
relocated TS will also be sumcarized in the appropriate section of the Final
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Safety Analysis Report (FSAR) Update.
The ECGS are controlled by a aepartment-level administrative procedure. The requirements described in the affected TS will be maintained, and any subsequent changes to the plant procedures or the FSAR Update related to these limits will be made in accordance with 10 CFR 50.59.
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I TS 3/4.7.2. " Steam Generator Pressure / Temperature limitation" I
t Pressure and temperature (P/T) limits are placed on the steam generators (SGs) l to prevent a nonductile failure of either the reactor coolant pressure boundary or the secondary side pressure boundary.
The specification places limits on the SG P/T to ensure that the pressure-induced stresses are within the Comission recently promdgated a proposed change to 10 CFR 50.36, pursuant to which the rule would be amerded to coolf y ard incorporate these criteria (59 FR 48130). The Commission's Final Policy Statenent specified that only limitir9 conditions for reactor Core isolation
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Cooling, Isolation Condenser, Residual Heat Removal, Standby Liquid Cont rol, and Recirculation 4
Pwp Trip seet the guidance for inclusion in the TS under Criterion 4 f,58 FR st 39137). The Comission has solicited public consnents on the scope of Criterico 4, in the pending rutemaking.
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I the maximum allowable fracture toughness stress limits.
The P/T limits are based on average SG impact values taken at 10 degrees Fahrenheit and are sufficient to prevent brittle fracture. Appendix G to 10 CFR Part 50 provides P/T limits for the reactor coolant pressure boundary, and TS requirements for SG tube surveillances ensure the integrity of the boundary between the reactor i
coolant system and the SG.
In addition, 10 CFR 50.55a provides requirements for inservice inspection, including that for the SG.
t Requirements related to the steam generator P/T limits do not satisfy any of the above final policy statement criteria which would necessitate that they be included in the TS.
This TS applies at shutdown conditions at low primary system temperature and pressure when the SGs are not required to mitigate DBAs or transients.
The requirements of the existing TS for the SG P/T limits are not requirements that identify a parameter that is an initial condition assumption for a DBA or transient, are not used to detect a significant abnormal degradation of the reactor coolant pressure boundary, and do not form part of the primary success path which fur ctions or actuates to mitigate a DBA or transient.
Therefore, the requirements specified in the existing TS have been relocated to the FSAR Update and will be controlled in accordance with 10 CFR 50.59 and 10 CFR 50.55a.
TS 3/4.7.7. " Snubbers" Snubbers are passive devices used for supporting piping systems. The restraining action of the snubbers ensures that the initiating event failure does not propagate to other parts of the failed system or to other safety systems.
Snubbers also allow normal thermal expansion of piping and nozzles to eliminate excessive thermal stresses during heatup or cooldown.
The existing TS action statement requires that an inoperable snubber be replaced or repaired within the allowed outage time. The surveillance requirement for snubbers is that they be periodically examined under the inservice inspection program in accordance with 10 CFR 50.55a.
Requirements related to the snubbers do not satisfy any of the final policy statement criteria which would necessitate that they be included in the TS.
Operability requirements of snubbers are not explicitly considered in the DBA or transient analysis. The requirement of the existing TS that all snubbers l
be operable is not a requirement that identifies a parameter that is an initial condition assumption for a DBA or transient, is not used to detect a significant abnormal degradation of the reactor coolant pressure boundary, and is not part of the primary success path which functions or actuates to l
Therefore, the requirements specified in the existing TS have been relocated to the FSAR Update and will be controlled in accordance with 10 CFR 50.59 and 10 CFR 50.55a.
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TS 3/4.7.8. " Sealed Source Contamination" The TS limitation ensures that leakage from byproduct, sourcs, and special nuclear material sources will not exceed allowable intake values.
The requirements of the existing TS, " Sealed Source Contamination," states that scaled sources containing radioactive material shall be.ree of a specified I
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. removable contamination. The limitations on removable contamination for sources requiring leak testing, including alpha emitters, is based on 10 CFR 70.39(a)(3) limits for plutonium. The associated action statement requires that if the removable contamination exceeds limitations, the sealed source i
shall be either disposed of or decontaminated.
Requirements related to sealed source contamination do not satisfy any of the final policy statement criteria which would necessitate that they be included in the TS. The limitations expressed in this TS are not requirements that identify a parameter that is an initial condition assumption for a DBA or transient, are not used to detect a significant abnormal degradation of the reactor coolant pressure boundary, and do not provide any mitigation of a design basis event.
Further, adequate requirements for controlling radiological contamination are specified in 10 CFR Part 20. Therefore, the requirements specified in the existing TS have been relocated to the FSAR Update and will be controlled in accordance with 10 CFR 50.59 and 10 CFR Part 20.
TS 3/4.7.11. " Area Temoerature Monitorina" This specification places a limit on the temperature of the areas of the plant which contain safety-related equipment. The requirements of the existing TS provide a means to assure that safety-related equipment will not be subjected to temperatures in excess of that assumed for the purpose of environmental qualification, and will therefore remain operable in order to perform intended safety functions.
However, these assumptions are also reflected in operability requirements associated with the TS limiting conditions for operation for the specific equipment.
Section 50.49 of 10 CFR Part 50 specifies environmental qualifica-tion requirements for safety-related electrical equipment. Accordingly, there is no need for a separate LC0 for area temperature.
Requirements related to area temperature monitoring do not satisfy any of the final policy statement criteria which would necessitate that they be included in the TS. This instrumentation does not otherwise measure parameters that are initial condition assumptions for a DBA or transient, is not used to i
detect a significant abnormal degradation of the reactor coolant pressure boundary, and does not provide for mitigation of design basis events.
Therefore, the requirements specified in these existing TS do not satisfy the e
criteria for TS, and have been relocated to the FSAR Update and will be i
controlled according to 10 CFR 50.59.
TS 3/4.7.13. " Flood Protection" The requirements of the existing TS, " Flood Protection," specify limiting conditions and surveillance requirements for those design features that provide protection against flooding for safety-related equipment.
The breakwaters (east and west) provide flood protection to the safety-related auxiliary salt water (ASW) pumps located in the intake structure. While there are flooding events included in the DBAs, these design features are passive and not associated with structures, systems or components that are assumed to 3...
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. actuate to prevent or mitigate a DBA or transient.
Further, the quality assurance program includes sufficient requirements for monitoring and maintaining the overall plant design, including the flooding protection features. The ongoing surveillance of the breakwaters will ensure that proper flood protection is provided for the ASW pumps. Therefore, the requirements specified in these existing TS do not satisfy the criteria for TS, and have been relocated to the FSAR Update and will be controlled according to 10 CFR 50.59.
3.0
SUMMARY
On the basis presented above, the staff concludes that the steam generator P/T limitation, snubber, sealed source contamination, area temperature monitoring, and flood protection requirements do not need to be controlled by TS and that changes to these requirements are adequately controlled by 10 CFR 50.59,
" Changes, tests, and experiments." Should the licensee's determination conclude that an unreviewed safety question is involved, due to either (1) an increase in the probability or consequences of accidents or malfunctions of equipment important to safety, (2) the creation of a possibility for an accident or malfunction of a different type than any evaluated previously, or (3) a reduction in the margin of safety, NRC approval and a license amendment would be required prior to implementation of the change. NRC inspection and enforcement programs also enable the staff to monitor facility changes and licensee adherence to FSAR Update commitments and to take any remedial action that may be appropriate.
The staff has concluded, therefore, that relocation of TS 3/4.7.2, 3/4.7.7, 3/4.7.8, 3/4.7.11, and 3/4.7.13 is acceptable because (1) their inclusion in TS is not specifically required by 10 CFR 50.36 or other regulations, (2) the requirements are not required to avert an immediate threat to the public health and safety, and (3) changes that are deemed to involve an unreviewed safety question will require prior NRC approval in accordance with 10 CFR 50.59(c).
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the California State official was notified of the proposed issuance of the amendments.
The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
These amendments change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (59 FR
0
- 17603). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).. Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors:
C. Grimes M. A. Miller Date:
July 6, 1995 i
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