ML20086M602
| ML20086M602 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 07/17/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20086M591 | List: |
| References | |
| NUDOCS 9507240366 | |
| Download: ML20086M602 (4) | |
Text
- f "%y Jg UNITED STATES S
NUCLEAR REGULATORY COMMISSION E
Uf WASHINGTON, D.C. 2056H001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.121TO FACli.1TY OPERATING LICENSE NO. NPF-10 AND AMENDMENT NO.110TO FACILITY OPERATING LICENSE NO. NPF-15 SOUTHERN CALIFORNIA EDISON COMPANY SAN DIEGO GAS AND ELECTRIC COMPANY THE CITY OF RIVERSIDE. CALIFORNIA THE CITY OF ANAHEIM. CALIFORNIA SAN ON0FRE NUCLEAR GENERATING STATION. UNITS 2 AND 3 DOCKET NOS. 50-361 AND 50-362
1.0 INTRODUCTION
By letter dated September 3, 1992, Southern California Edison Company, et al.
(SCE or the licensee) submitted a request for changes to the Technical Specifications (TS) for San Onofre Nuclear Generating Station, Unit Nos. 2 and 3.
The proposed changes would revise TS 3/4.4.8, " Pressure / Temperature Limits-Reactor Coolant System," and their associated Bases by removing the withdrawal schedules for the reactor vessel material irradiation surveillance specimens in response to guidance provided in Generic Letter 91-01, " Removal of the Schedule for Withdrawal of Reactor Vessel Material Specimens from Technical Specifications."
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 technical specifications are set forth in 10 CFR 50.36.
That regulation requires that the TS include items in five specific categories, including (1) safety limits, lir.iting safety system settings and limiting control settirgs; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls.
- However, the regulation does not specify the particular requirements to be included in a plant's TS.
The Commission has provided guidance for the contents of TS in its " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (" Final Policy Statement"), 58 Fed. Reg. 39132 (July 22,1993), in which the Commission indicated that compliance with the final policy statement 9507240366 950717 PDR ADOCK 05000361 p
e
, satisfies ll82a of the Act.
In particular, the Commission indicated that 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 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 obv"te the possibility of an abnormal situation or event giving rise to an hnmediate 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 to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; (2) a process variable, design feature, or operating restriction that is an initial condition of a design basis accident 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 design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier; (4) a structure, system, or component which operatingexperienceorprobabilisticsa[etyassessmenthasshowntobe significant to public health and safety.
As a result, existing TS requirements which fall within or satisfy any of the 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 TS 3/4.4.8, " Pressure / Temperature Limits - Reactor Coolant System," contains a limiting condition for operation for the reactor coolant system (RCS) that limits the rate of change in temperature and pressure to values consistent with the fracture toughness requirements of the American Society of Mechanical Engineers Code and Appendix G to Part 50 of Title 10 of the Code of Federal Regulations.
Changes in the values of these limits are necessary because the fracture toughness properties of ferritic materials in the reactor vessel change as a function of the reactor operating time.
For this reason, the present TS include Surveillance Requirement (SR) 4.4.8.1.2, which requires the removal and examination of the irradiated specimens of reactor vessel material.
The licensee examines the specimens to The Consnission recently promulgated a proposed change to 10 CFR 50.36, pursuant to which the rule would be amended to codify and incorporate these criteria (59 FR 48180). The Cununission's Final Policy Statement specified that only limiting conditions for reactor Core Isolation Cooling, Isolation Condenser, Residual Heat Removat, Standby Liquid Control, and Recirculation Ptsrp Trip meet the guidance for inclusion in the TS under Criterion 4 (58 FR at 39137). The Consnission has solicited public consnents on the scope of Criterion i
4, in the pending rulemaking.
~
. determine the changes in material properties in accordance with the requirements of Appendix H to 10 CFR Part 50.
TS Table 4.4-5 specifies the schedule for removal of each capsule. The removal of the schedule for withdrawing material specimens from the TS will eliminate the necessity of a license amendment to make changes to this schedule.
The staff's review of the proposed change determined that the relocation of the withdrawal schedules does not eliminate the requirements for the licensee to ensure that the reactor vessel is capable of performing its safety function.
Section I.B.3 of Appendix H to 10 CFR Part 50 requires the submittal of a proposed withdrawal schedule for material specimens to the NRC and approval by the NRC before implementation.
Hence, adequate regulatory controls exist to control changes to this schedule without the necessity of subjecting it to the license amendment process by including it in the TS.
The licensee has committed to include this withdrawal schedule in the next revision of the Updated Final Safety Analysis Report (UFSAR). Although the withdrawal schedules are relocated from the technical specifications to the UFSAR, the licensee must continue to evaluate any changes to the schedule in accordance with 10 CFR 50.59 and Appendix H to 10 CFR Part 50.
Should the l
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 j
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 UFSAR commitments and to J
take any remedial action that may be appropriate.
i The staff's review concluded that 10 CFR 50.36 does not require the withdrawal schedule to be retained in technical specifications. Requirements related to the operability, applicability, and surveillance requirements, including performance of testing to ensure operability of the reactor vessel is retained due to the reactor vessel's importance in mitigating the consequences of an accident. However, the staff determined that the inclusion of the withdrawal schedules are an operational detail related to the licensee's safety analyses which are adequately controlled by the requirements of 10 CFR 50.59.
Therefore, the continued processing of license amendments related to revisions of the affected withdrawal schedules, where the revisions to those requirements do not involve an unreviewed safety question under 10 CFR 50.59, would afford no significant benefit with regard to protecting the public l
health and safety.
The staff has concluded, therefore, that relocation of the withdrawal schedules for the reactor vessel material irradiation surveillance specimens is acceptable because (1) Appendix H to 10 CFR Part 50 provides adequate regulatory guidance for this issue, (2) their inclusion in technical specifications is not specifically required by 10 CFR 50.36 or other j
regulations, (3) the withdrawal schedules have been relocated to the UFSAR,
j
, are adequately controlled by 10 CFR 50.59, and their inclusion in the TS is not required to avert an immediate threat to the public health and safety, and (4) changes that are deemed to involve an unreviewed safety question, will require prior NRC approval in accordance with 10 CFR 50.59(c).
The following editorial corrections are being made on the affected TS pages:
1.
Unit 2 TS page 3/4 4-27a is being renumbered 3/4 4-28 with the deletion of Table 4.4.5 on 3/4 4-28.
2.
Unit 2 TS section 4.4.8.1.2.a and footnote
" plates" should be " plate."
3.
Unit 3 TS page 3/4 4-28a is being renumbered 3/4 4-29 with the deletion of Table 4.4.5 on page 3/4 4-29.
These changes are strictly administrative in nature and are acceptable.
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the California State official was notified of the proposed issuance of the amendment.
The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
The 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 considera-tion, and there has been no public comment on such finding (58 FR 8781).
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.
5.0 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 amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
D. Skay Date:
July 17, 1995
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