ML20086N718

Amend Applications 148 & 132 to Licenses NPF-10 & NPF-15, Respectively,Consisting of Proposed Change Number (PCN)-423. PCN-432 Revises TS Re Radiation Monitoring Sys

ML20086N718
Person / Time
Site:	San Onofre
Issue date:	07/19/1995
From:	Rosenblum R SOUTHERN CALIFORNIA EDISON CO.
To:
Shared Package
ML20086N716	List: ML20086N713 ML20086N718 ML20086N721
References
NUDOCS 9507250308
Download: ML20086N718 (12)

Text

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..II UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA

)

Docket No. 50-361 L

EDIS0N COMPANY, H R.

for a Class 1,03

)

R License.to Acquire, Possess,.and Use

)

a Utilization Facility as Part of

)

Amendment Application Unit No. 2 of the San Onofre Nuclear

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No. 148 Generating Station

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SOUTHERN CALIFORNIA EDIS0N COMPANY, H E. pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 148.

This amendment application consists of Proposed Change Number (PCN)-432 to Facility Operating License No. NPF-10.

PCN-432 revises Unit 2 Technical Specification (TS) Tables 3.3.3, " Engineered Safety Feature Actuation System Instrumentation," 3.3-4, " Engineered Safety Feature Actuation System Instrumentation Trip Values," 3.3-5, " Engineered Safety Features Response Times," 4.3-2, " Engineered Safety Feature Actuation System Instrumentation Surveillance Requirements," 3.3-6, " Radiation Monitoring Instrumentation," and 4.3-3, " Radiation Monitoring Instrumentation Surveillance Requirements."

9507250308 950719 DR ADOCK 0500 1

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Subscribed on this l9 TN day of JuLV

,1995 Respectfully submitted, SOUTHERN CALIFORNIA EDISO ; COMPANY

/N By:

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Richltrd M. 'RgYenblum 2

a Vice President i

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state of California County llofOrange be, fore me, $ARAAR A A ficCARTHYfNCTAf y' PuALics, i

On 9 1/95 personally appeared Rie nM AD M Rese vac u 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.

i WITNESS my hand and official seal.

j Signature

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1 My Comm Epos MAR 31. Igge g i

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UNITED STATES OF. AMERICA

)

J NUCLEAR REGULATORY COMMISSION I

s Application of SOUTHERN CALIFORNIA

)

Docket No. 50-362 EDIS0N COMPANY, EI AL.

for a Class 103

)

l License to Acquire, Possess, and Use

)

l a Utilization Facility as Part of

)

Amendment Application t

Unit No. 3 of the San Onofre Nuclear

)

No. 132 Generating Station

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SOUTHERN CALIFORNIA EDIS0N COMPANY, El AL. pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 132.

This amendment application consists of Proposed Change Number (PCN)-432 to Facility Operating License No. NPF-15.

PCN-432 revises Unit 3 Technical l

Specification (TS) Tables 3.3.3, " Engineered Safety Feature Actuation System j

Instrumentation,".3.3-4, " Engineered Safety Feature Actuation System j

Instrumentation Trip Values," 3.3-5, " Engineered Safety Features Response f

Times," 4.3-2, " Engineered Safety Feature Actuation System Instrumentation Surveillance Requirements," 3.3-6, " Radiation Monitoring Instrumentation," and 4.3-3, " Radiation Monitoring Instrumentation Surveillance Requirements."

s t

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Subscribed on this

/9 M day of Jac

,1995.

)

Respectfully submitted, 1

i SOUTHERN CALIFORNIA EDIS0N COMPANY t4

./

/

By:

RichhiFd M. /Rosenblum i

Vice President State of California County /19/95 before me, BAf8AKA A. McentruY/miny Acu'e of Orange on '1 s

personally appeared 7/cNA/D M. brevBLupt

. 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 2 M /s O.

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anna m A. M e c.e w I, co-,

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Nelev M4Ae - CeAlande 3 m

CEMGE COUNW r

j MrComm.Essees MAR 31.19995 r - - - - - -

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DESCRIPTION AND SAFETY ANALYSIS 0F PROPOSED CHAN9E NPF-10/15-432

'This is a request to revise Technical Specification (TS) Tables 3.3-3,

" Engineered Safety Feature Actuation System Instrumentation," 3.3-4, l

" Engineered Safety Feature Actuation System Instrumentation Trip Values,"

7 3.3-5, " Engineered Safety Features Response Times," 4.3-2, " Engineered Saf6ty l

Feature Actuation System Instrumentation Surveillance Requirements," 3.3-6, l

" Radiation Monitoring Instrumentation," and 4.3-3, " Radiation Monitoring Instrumentation Surveillance Requirements."

Existino Specifications Unit 2:

See Attachment "A" Unit 3:

See Attachment "B" Proposed Specifications Unit 2:

See Attachment "C" Unit 3:

See Attachment "D" t

Technical Specification Improvement Procram (TSIP) PCN-299 Existino SDecifications Unit 2:

See Attachment "E" Unit 3:

See Attachment "F" Proposed Specifications Unit 2:

See Attachment "G" Unit 3:

See Attachment "H" i

DESCRIPTION Proposed changes to the existing TSs (see Attachments C and D):

Table 3.3-3 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION Under Functional Unit 9, Control Room Isolation (CRIS):

o In 9.c, add " Control Room" to " Airborne Radiation."

Under Functional Unit 12, " Containment Purge Isolation (CPIS):

o In 12.b, add " Containment" to " Airborne Radiation."

0 In 12.c, delete the Containment Area Radiation Monitors.

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Table 3.3-4 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION TRIP VALUES Under Functional Unit 9, Control Room Isolation (CRIS):

o In 9.c, add " Control Room" to " Airborne Radiation." In addition.

i change the Trip Value and Allowable Value by reference to Note (7).

Under Functional Unit 12, Containment Purge Isolation (CPIS):

o In 12.b, add " Containment" to " Airborne Radiation," and delete the reference to Note 7 for the monitor Trip Values and Allowable Values.

o In 12.c, delete the Containment Area Radiation Monitors.

Under Table Notation for Table 3.3-4:

o Change Note 7 to read "The trip setpoint shall be set sufficiently high to prevent spurious alarms / trips yet sufficiently low to assure an alarm / trip to isolate the control room for habitability during and following accident conditions."

Table 3.3-5 ENGINEERED SAFETY FEATURES RESPONSE TIMES Under Initiating Signal and Function 16:

o Delete the Containment Area Radiation Monitors from CPIS.

Table 4.3-2 ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE RE0VIREMENTS i

Under Functional Unit 9, Control Room Isolation (CRIS):

o Add " Control Room" to " Airborne Radiation."

Under Functional Unit 12, Containment Purge Isolation (CPIS):

o In 12.b, add " Containment" to " Airborne Radiation."

o In 12.c, delete the Containment Area Radiation Monitors.

Table 3.3-6 RADIATION MONITORING INSTRUMENTATION Under Instrument 1, Area Monitors:

o Delete the Containment Area Radiation Monitors.

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Table 4.3-3 RADIATION MONITORING INSTRUMENTATION SURVEILLANCE RE0VIREMENTS Under Instrument 1, Area Monitors:

o Delete the Containment Area Radiation Monitors.

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For each of the above deletions, add the word " Deleted" to the Technical Specifications.

Proposed changes to the TSs post PCN-299 (see Attachments G and H):

TS 3.3.8 Containment Purae Isolation Sianal (CPIS)

Under Condition A:

o Replace " area" with " airborne."

Under Condition C:

o Add " containment," before " airborne."

Under Condition D:

o Add " containment airborne," before " radiation."

Under SR 3.3.8.1:

o Replace " area and gaseous" with " airborne."

Under SR 3.3.8.2:

o Delete the Note.

o Add " airborne" before " radiation" and " trip" before setpoint, and delete " Allowable Value."

o Replace " Gaseous" before " Monitor" with " Airborne Radiation."

o Replace "5 2X background" with " set sufficiently high to prevent spurious alarms / trips yet sufficiently low to assure an alarm / trip should an inadvertent release occur." This change allows relocation of the setpoint and allowable values to the administrative control procedures and is consistent with the J

existing Containment Airborne Radiation Monitor TSs.

o Delete the reference to the Containment Area Gamma Monitor setpoint.

Under SR 3.3.8.3:

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i o

Delete existing SR 3.3.8.3 since its requirements are now incorporated in SR 3.3.8.2.

Under SR 3.3.8.4:

i o

Renumber existing SR 3.3.8.4 to SR 3.3.8.3.

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Under SR 3.8.3.5:

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o Renumber existing SR 3.3.8.5 to'SR 3.3.8.4 and add " airborne" before " radiation."

Under SR 3.3.8.6:

l o

Renumber existing SR 3.3.8.6 to SR 3.3.8.5.

j Under SR 3.3.8.7:

o Renumber existing SR 3.3.8.7 to SR 3.3.8.6.

TS 3.3.9 Control Room Isolation Sianal (CRIS)

Under Conditions A and B:

o Replace " particulate / iodine or gaseous" before " radiation" with

" control room airborne." Deletion of " particulate / iodine" was-also t

addressed in PCN-405.

Under SR 3.3.9.1:

o Add " airborne" before " radiation."

Under SR 3.3.9.2:

j t

o Add " airborne" before " radiation."

Replace "s4E2 cpm above normal background" with " set sufficiently l

o high to prevent spurious alarms / trips yet sufficiently low to j

assure an alarm / trip to isolate the control room for habitability during.and following accident conditions." The change is made to allow relocation of the setpoint and allowable-values to the administrative control procedures and is consistent with the existing Containment Airborne Radiation Monitor TSs.

Under SR 3.3.9.4:

o Add " airborne" before " radiation."

DISCUSSION The proposed changes to the existing TSs in Attachments C and D allow implementation of modifications to the Containment Area Radiation Monitors.

These modifications.are part of the proposed DCP-6926 to delete or-upgrade / replace existing Nuclear Measurements Corporation (NMC) Radiation Monitoring System (RMS) equipment with modern state-of-the-art microprocessor-based equipment.

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The Containment Area Radiation Monitors 2(3) RT-7856-1 and 2(3) RT-7857-2 are designed to sense a Loss of Coolant Accident (LOCA) or Fuel Handling accident inside containment during a containment purge and initiate the Containment Purge Isolation System (CPIS) to close the purge valves.

In addition to the Containment Area Radiation Monitors CPIS actuation signals are also provided by Containment Airborne Radiation Monitors 2(3) RT-7804-1 and 2(3) RT-7807-2.

The Containment Airborne Radiation Monitors 1) alarm on high radiation level and initiate CPIS in the event of a Fuel Handling accident inside containment,

2) alarm on high radiation level and initiate CPIS, terminating purge releases, in the event of a LOCA event inside containment, 3) alarm on high radiation level and initiate CPIS, terminating purge releases, prior to activity levels exceeding 10 CFR 20 Appendix B limits, and 4) detect a primary-to-containment atmosphere leak rate change of 1 gal / min in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> consistent with the recommendations of Regulatory Guide (RG) 1.45, " Reactor Coolant System Pressure Boundary Leakage Detection Systems for Nuclear Power Plants."

The proposed change removes the Containment Area Radiation Monitors'

[2(3)RT-7856-1 and 2(3)RT-7857-2] Engineered Safety Actuation System (ESFAS) function to initiate CPIS on high radiation in containment. This proposed 1

modification will eliminate the need for containment entries during power operations to perform maintenance or repair for these monitors. This proposed modification meets the requirements of 10 CFR 50, Appendix A, General Design Criteria 54, 56, and 60.

This proposed change, which is consistent with PCN-299, reduces the diversity of radiation sensing in containment for CPIS generation from four types of radioactivity to one type as discussed in the safety analysis section of this proposed change.

The proposed change also removes the setpoint and allowable values for the Control Room Airborne Radiation Monitors from the TSs. This change makes the Control Room Airborne Radiation Monitor TSs consistent with the Containment Airborne Radiation Monitor TSs. The actual values will be administratively controlled by quality-affecting procedures (i.e., changes to procedures will be evaluated under 10 CFR 50.59).

Editorial changes are for clarity and consistency.

The markups in Attachments G and H revise the TSs post PCN-299 to reflect PCN-432 changes and PCN-405 changes to the Control Room Airborne Radiation i

Monitors.

SAFETY ANALYSIS The proposed change described above shall be deemed to involve a significant hazards consideration if there is a positive finding in any one of the 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 5

Control Room Airborne Radiation Monitors The proposed change would permit relocation of the setpoint and allowable values for the monitors from the Technical Specifications (TSs) to the administrative control procedures.

This change is consistent with the existing Containment Airborne Radiation Monitor TSs.

This change will not prevent the radiation monitors from performing their intended function following a design basis accident. Therefore, operation of the facility in accordance with this change will not involve a significant increase in the probability or consequences of an accident previously evaluated.

Containment Area Radiation Monitors lhe proposed change deletes the existing Containment Area Radiation Monitors RE-7856-1 and RE-7857-2 and their Engineered Safety Feature Actuation System (ESFAS) function to initiate containment purge isolation on high radiation in containment.

The deletion of this ESFAS function does not create a precursor to any analyzed accident since these monitors are for accident mitigation only.

Currently, no release of radioactivity is assumed during a Fuel Handling Accident in containment since the Containment Area Radiation Monitors detect and isolate containment purge prior to release. The proposed deletion will cause some release prior to detection and isolation of purge by the remaining noble gas containment monitors. The consequences of a Fuel Handling Accident inside containment were previously re-evaluated, assuming no containment purge isolation, to resolve inconsistencies in the original analysis assumptions and methodology.

The results of the calculation indicated off-site doses well within the limits of 10 CFR 100 and Control Room doses that met the limits of 10 CFR 50 Appendix A General Design Criterion 19. Containment purge isolation on high gaseous activity during a Fuel Handling Accident will still be available with this proposed change but is not required for the dose consequences to remain within the dose criteria. Therefore, the proposed change will not significantly increase the consequences of a Fuel Handling Accident inside containment.

The Loss of Coolant Accident (LOCA) function of the Containment Purge Isolation System (CPIS) signal will be essentially unaffected by this proposed change.

Currently, containment purge isolation (containment minipurge) on high radiation signals is a diverse signal with Safety Injection Actuation System (SIAS) and Containment Isolation Actuation System (CIAS).

In a LOCA event, containment purge isolation is expected to occur on either SIAS or CIAS prior to a CPIS signal on high radiation in containment. While this proposed change reduces the diversity of radiat' ion monitoring inputs, the diversity of parameters measured (pressure and radiation) is still preserved.

Therefore, the proposed change will not increase the consequences of a LOCA.

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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 control Room Airborne Radiation Monitors Relocating the' monitor setpoint and allowable values from the TSs to the administrative procedures would not alter the design and operational-interface between the Control Room Isolation System instrumentation and existing plant-equipment. As such, the monitors would continue to operate and perform their intended safety function to isolate the control room following a design basis accident as before. Therefore, operation of the facility in accordance with this proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

Containment Area Radiation Monitors The deletion of the Containment Area Radiation Monitors will not alter the operation of CPIS.

The remaining interface between CPIS and existing plant equipment will continue to perform their intended safety function to isolate containment purge by closing the containment purge valves. This function will continue to be performed by Containment Airborne Radiation Monitors 2(3) RT-7804-1 and 2(3) RT-7807-2.

Therefore, operation of the facility in accordance with this proposed change will 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?

Response

No Control Room Airborne Radiation Monitors Relocating the monitor setpoint and allowable values to the administrative procedures would not alter the existing margin of safety.

The relocation would only relinquish control of the setpoint and allowable values from the TSs to quality-affecting (changes will require a 10 CFR 50.59 evaluation) procedures. Therefore, operation of the facility will not involve a significant reduction in a margin of safety.

Containment Area Radiation Monitors The proposed change does not affect the margin of safety in Modes 1 through 4 since the diversity of the parameters measured is maintained for minipurge isolation.

Either SIAS, CIAS, CPIS, or manual operation'

.will close the containment mini purge valves. The main purge is sealed closed during Modes I through 4 with the purge valves closed and deactivated.

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e The diversity of the parameters measured is not maintained for the containment main purge isolation. The main purge is only applicable during Modes 5 and 6 and main purge isolation is initiated only by either CPIS or manual operation.

This proposed change along with the previously submitted PCN-299 reduces the diversity of radiation sensing in containment for CPIS generation from four types (gaseous, iodine, particulate, ana gamma) to one type (gaseous activity).

Since the consequences of a Fuel Handling Accident inside containment without purge isolation have been calculated to be well within 10 CFR 100 dose limits, the loss of diversity for this accident does not result in a significant reduction in a margin of safety. Therefore, this proposed change will not involve a significant reduction in a margin of safety.

Safety and Sionificant 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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