ML20106J958

Safety Evaluation Supporting Amends 24 & 13 to Licenses NPF-10 & NPF-15,respectively

ML20106J958
Person / Time
Site:	San Onofre
Issue date:	09/24/1984
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20106J925	List: ML20106J920 ML20106J958
References
TAC-51613, TAC-55119, NUDOCS 8411010407
Download: ML20106J958 (4)

Text

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v SAFETY EVALUATION

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AMENDMENT N0. 24 TO NPF-10 AND 13 TO NPF-15 SANONOFRENUCLEARGENERATINGSTATION(SONGS), UNITS _2jND3 DOCKET NOS. 50-361 AND 50-362 Introduction and Sumary

. By letters dated July 23,.1982, August 16, 1982, December 17, 1982, January 28, 1983, January 25, 1984, and April 13, 1984, the licensees (Southern California Edison. Company, San Diego Gas and Electric Company, the City.of Anaheim, Cali-fornia, and the City.of Riverside, California) requested that amendments'be issued to Facility Operating Licenses NPF-10 and NPF-15 for operation of the, San Onofre Nuclear Generating Station", Units 2 and 3.

The proposed change would revise note (4) of Table 4.3-2 of Technical Specifi-cations 3/4.3.2, Engineered Safety Features Actuation System (ESFAS) Instrumen-tation, to exempt from testing during plant operation the 23 subgroup relays 1

associated with ESFAS equipment which cannot be safely actuated during plant operation or would trip the plant. -The proposed change would require testing.

of each of 'these 23 relays during each cold shutdown of duration exceeding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unless the relay was tested during the previous six months. Since the maximum operating time between refuelings'is 18 months, the maximum interval between testing of ESFAS subgroup relays exempted from testing during power

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operation by the proposed change is 18 months, although it may be less. There-fore, the proposed change will result in a change in the maximum surveillance 1

interval of the 23 affected relays from 6 months to 18 months.

Background

Based on the NRC staff's review of the application for operating licenses,'

it was the staff's understanding that the SONGS 2 and 3 design complied with the provisions of Regulatory Guide (R.G.) 1.22 and IEEE Standard-338. The staff understood during the OL review that all subgroup relays within the protection system could be tested with the plant at power. This included all the ESFAS subgroup relays associated with the actuated equipment (various valves) listed in FSAR Table 7.3-16A even thcugh the equipment itself cannot i

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1. be operated:while the plant,is'at power.- The licensees-committed to meet R.G?,

cqgg. ;.1.22-and IEEE-338 in Sections 7.2.1.1.9 and 7.3.1.1.1.9 of the FSAR and-' agreed- '

P E tola 6-month' surveillance requirement for all ESFAS : subgroup relays during..

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development of the' SONGS ~ Technical Specifications.

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.i Subsequently, the lic~ensees-infdrmed the staff by Ietter dated July..23, 1982?

and in a meeting on July.29.,'1982, that the SONGS 2 and;3 design does not'

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rallow the subgroup ~ relays associated with the. actuated equipment identified-t in FSAR Table 7.3-16A.to' be ; tested during. reactor operation. ' The. staff then

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. requested that the licensees justify the adequacy of..the protection system design with respect to the capability for testing at power..The~ staff noted, v

that it.would grant exceptions to the 6-month test-interval for cases where.

1 iths subgroup 1 relay;is-associated with actuated equipment that cannot be oper.

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ated while' the. plant is-at power, provided that a plant ~ specific justification

'is provided to demonstrate that relay assignments.have been made in a manner

'that minimizes theinumber which cannot be, tested = at power and that the relay -

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= testing which will be performed is: sufficient to verify continuing high reli-ability of'the protection system. The licensees' responded to the above~ staff request by letters dated August 16, 1982, December - 17,1982 and January 28, 1983.. By letter dated. January 25,1984, the licensees-proposed the technical specification change described'above. The staff's evaluation of the proposed -

technical specification change is discussed below.

Evaluation The licensees'LJa'nuary 28, 1983 letter includes a table which identifies all the active ESFAS' subgroup relays (102 total) and defines which can and'cannot be tested while~ the plant-is 'at power. For the 23 relays that cannot be tested during plant operation, the licensees _ have provided the rcquired justification.

The staff has~ reviewed the information and finds it acceptable since it appears that testing of the 23 subgroup relays while' the plant is at power could adversely

. affect plant safety or operability. Also, the actuated equipment: assignments to the subgroup relays were made in a manner to minimize the number of components which cannot be tested with. the plant at power. The staff has also determined that the reliability of the. subgroup relays can be adequately maintained and verified through the six month periodic testing 'of those relays which can be :

tested at' power in conjunction with the testing of the' remaining relays when ~

'the plant is-in a cold shutdown condition.

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After being advised of the staff's conclusions described above, the: licensees,,

i by'1etter dated January 25, 1984, proposed to incorporate this ESFAS subgroup

< relay test -requirement into the SONGS Technical Specifications by modifying

' ' Note (4) to Table 4.3-2 to read:

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"(4) A subgroup relay test shall be performed which

-shall include the energization/deenergization 9-of each subgroup relay and verification of the OPERABILITY of each subgroup relay. Relays J'

' exempt from testing during plant operation 1shall be limited only to those relays associ-p'

'ated with equipment which cannot be operated j

_during plant operation. Relays not. testable during plant operation--shall be tested during each COLD SPUTDOWN exceeding E4 hours unless

. tested during the previous 6 months."

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-This;, note will%nsure that the testing requirements,for all but a limited :

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' number. 2 of: subgroup relays are' consistent with the' provisions of the regula-

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, - ' tory guidance provided in R.G.1.22 and--IEEE-338 (i.e6 the subgresr relays-

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which a're: associated with actuated equipment that"can.be operated at' power-willsbeitested every 6: months). : Since all thelESFAS : subgroup-relays-for, s

n SONGS'are the 'same' type, the-6. month-surveillance. testing for those (79).

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Lthatlcan be operated while at power in conjunction with the less, frequent 1

required testing

of the remaining relays will provide sufficient, plant

- i F specific' operational data' to verify. the reliability of all the relays..,0n u this1 basis, the staff, finds ~the_ proposed; change to beLacqeptable.'

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1 Contact With State Official:

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~B'y. copy of a letter dated July'6,1984 to thd ' licensees, the NRC staff adv'ised

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the Chief of the Radiological: Health Branch, State Department of Health Services,

. State. of. California, of its: proposed determination ~of no significant hazards Jconsideration. No coments ~were received.

Environmeiital Consideration t

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The amendments. involve a change.in the installation or use. of'a facility com-ponent 1ocated within the restricted. area as defined in 10 CFR Part 20. :The-j staff has detennined that the amendments involve no significant increase in

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the amounts, and no significant change in the types, of 'any effluents.that p

may be released offsite, and that there is no significant. increase-in'i_ndivi-dual or cumulative; occupational radiation exposure. ; The Comission has pre-vicusly issued a proposed finding that this! amendment involves no significant o

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hazards-consideration and there has been.no public coment on such: finding.

Accordingly, the anendments meet the eligibility criteria for. categorical-i

exclusion ~setforth-inCFR51.22(c)(9).- Pursuant to 10 CFR 51.22(b), no,

environmental. assessment need be preparedLin connection with the issuance of the a'mendments.-

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Conclusion,.

l Based.upcn our evaluation of the proposed changes to the han-Onofre 2 and 3 Technical Specifications, we have concluded that: there is reasonable 'assur-

-ance' that-the health and safety of the public will not be endangered by.

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operation zin the proposed manner, and such activities will be conducted in - -

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compliance with the Comission's regulations and the issuance of this amend-ment will. not be inimical to the common defense and security or to the health and safety.of the public..We, therefore, conclude that the proposed changee.

are acceptable.

10ated:

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i ISSUANCE'0F AMENDMENT NOS 24 AND 13 TO FACILITY OPERATING LICENSES NPF-10 AND NPF-15 SAN ON0FRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 DISTRIBUTION (Docket;liles.505361;and;50-362 u m,

NRC PDR Local POR PRC System NSIC LB#3 Reading J. Lee (7)

H. Rood T. Novak J. Saltzman, SAB L. Chandler, OELD C. Miles H. Denton-J. Rutberg A. Toalston W. Miller, LFMB N. Grace E. Jordan L. Harmon D. Brinkman, SSPB T. Barnhart (4)

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