ML20107B978

Application for Amends 158 & 142 to Licenses NPF-10 & NPF-15,respectively,revising TS 3.6.3, Containment Isolation Valves, to Resolve Inconsistency in TSs

ML20107B978
Person / Time
Site:	San Onofre
Issue date:	04/11/1996
From:	Nunn D SOUTHERN CALIFORNIA EDISON CO.
To:
Shared Package
ML20107B960	List: ML20107B978 ML20107B989
References
NUDOCS 9604170168
Download: ML20107B978 (8)

Text

a UNITED STATES OF AMERICA I NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA EDIS0N COMPANY, H E. for a Class 103 ) Docket No. 50-361

)

License to Acquire, Possess, and Use a Utilization Facility as Part of )

) Amendment Application Unit No. 2 of the San Onofre Nuclear ) No. 158 Generating Station

)

SOUTHERN CALIFORNIA EDIS0N COMPANY, H R . pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 158.

This amendment application consists of Proposed Change Number (PCN)-460 to facility Operating License No. NPF-10. PCN-460 is a request to revise the Unit 2 Amendment No.127 approved Technical Specification (TS) 3.6.3,

" Containment Isolation Valves," to resolve an inconsistency in the TS. The proposed change will provide Completion Times (cts) for Sections D.1 and D.2 valves which are consistent with the cts for the valves in the systems in which they are installed.

9604170168 960411 PDR P

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Subscribed on this b day of i)Pt j , 1996 ,

i Respectfully submitted, SOUTHERN CALIFORNIA EDI. SON COMPANY l

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ght E. Nunn V e President State of California County of San Diego r on hI f b)fk# hf efore_me, [I( k/l-6 L fl'} b ,

perso6 ally appeared (OlCi h,P ' 6 Utla n , personally known to me to be the person whose 6ame 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.

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WITNESS my nd and official seal

• j MAutANESAN H Signature! D '

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f3 Notory Pubbe Co femio ORANGE COUNT /

j Mr Comm. Err.,iros OCT Id. IM3

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UNITED STATES OF AMERICA l NUCLEAR REGULATORY COMMISSION i

Application of SOUTHERN CALIFORNIA ) Docket No. 50-362

.i EDIS0N COMPANY, H R. for a Class 103 )

license to Acquire, Possess, and Use )

i a Utilization Facility as Part of ) Amendment Application i Unit No. 3 of the San Onofre Nuclear ) No. 142 1 Generating Station )

SOUTHERN CALIFORNIA EDIS0N COMPANY, H R. pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 142.  !

This amendment application consists of Proposed Change Number (PCN)-460 to l Facility Operating License No. NPF-15. PCN-460 is a request to revise the l 5

Unit 3 Amendment No. 116 approved Technical Specification (TS) 3.6.3,

" Containment Isolation Valves," to resolve an inccnsistency in the TS. The proposed change will provide Completion Times (cts) for Sections D.1 and D.2 valves which are consistent with the cts for the valves in the systems in which they are installed.

4

4 Subscribed on this day of 'hfti

/ , 1996.

f Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY By:

C k- ~

Dwi 1t E. Nunn Vic President  :

1 State of California Cou ty of San Diego q On IhIl! 3 persdially appeared b ore me k[Y djiD

,014 d'E. ' M I) M4 )

, personally known to me to be the person whose ndme 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 [fwhichthepersonacted,executedtheinstrument. - - , , , , , , , , ,

WITNESS an nd o icialsealf -

g MARIANE SANCHQ COW 41033763 f

Signatur'i f

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Notory Phe - Co fornia ORANGE COLNTY f

( 1 Comm. E.pkes OCT 14,1993

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s DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-10/15-460 This is a request to revise Unit 2 Amendment No. 127 and Unit 3 Amendment No.

116 approved Technical Specification (TS) 3.6.3, " Containment Isolation Valves," for the San Onofre Nuclear Generating Station. Specifically, the Completion Times (cts) for Sections D.1 and D.2 valves are proposed to be revised to resolve an inconsistency in the TS.

Amendment Nos. 127 and 116 Approved Specifications Unit 2: See Attachment "A"

. Unit 3: See Attachment "B" i

Proposed Specifications Unit 2: See Attachment "C" i

Unit 3: See Attachment "D" DESCRIPTION TS 3.6.3, " Containment Isolation Valves," requires that Section D.1 and D.2 valves be secured in their Engineered Safety Feature Actuation Signal (ESFAS) actuated position within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of becoming inoperable. This requirement is intended to ensure these valves will be able to perform their ESFAS functions.

However, the Completion Times (cts) for these valves in their ESFAS function TSs are considerably longer than the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allowed in TS 3.6.3. To resolve this inconsistency, Southern California Edison (Edison) proposes to revise TS 3.6.3 to require use of the appropriate cts for Section D.1 and D.2 valves as follows:

Under the Completion Time for Required Actions E.1 and F.1, change "4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />" to "In accordance with the applicable LC0 pertaining to the valve or system in which it is installed."

This proposed change will restore the cts for Required Actions E.1 and F.1 to the pre-Amendment Nos. 119 and 108 cts for D.1 and 0.2 valves. There is no change to the Bases for Required Actions E.1 and F.1.

DISCUSSION Section D.1 and D.2 valves in TS 3.6.3, " Containment Isolation Valves,"

provide containment isolation and ESFAS functions. These valves are opened for their ESFAS function and closed for their containment isolation function.

Because of this dual function, the appropriate TSs governing the valves or systems in which these valves are required to be operable for ESFAS and TS 3.6.3 are entered simultaneously when they become inoperable. Therefore, it is important that the cts for the required actions between these TSs are consistently applied, f

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j For example, when one or more High Pressure Safety Injection (HPSI) Section D.1 valve becomes inoperable, both TSs 3.5.2, "ECCS-Operating, and 3.6.3 are entered. TS 3.5.2, which is the TS for the system in which these valves are installed, permits a 72-hour CT to return these valves to operable status. On the other hand, the initial action for containment isolation valve TS 3.6.3 requires that the valves be secured in their ESFAS actuated position within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after becoming inoperable. Thus, there is an inconsistency in the cts between these TSs.

This inconsistency between the TSs imposes a very restrictive CT for TS 3.6.3 action and prevents on-line maintenance of these valves. For example, if a valve is placed or fails in its intermediate position during Motor-0perated '

Valve Actuator Testing, both TSs 3.5.2 and 3.6.3 are applicable. In such a case where more than one action simultaneously applies, the more restrictive 4-hour CT of TS 3.6.3, not the 72-hour CT of TS 3.5.2, must be followed. This i could potentially result in a plant shutdown since 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> may not be sufficient time for a failed valve to be repaired and returned to operable status.

The inconsistency in the time to take initial action for D.1 and D.2 valves  !

l was inadvertently created in Amendment Nos. 119 and 108 due to an oversight in the associated Proposed Change Number (PCN)-430. PCN-430 was a request to revise TS 3.6.3 to add the requirements of Actions E.2 and F.2 based on the results of a Probabilistic Risk Assessment (PRA) which established specific limits on the length of time D.1 and D.2 valves may be placed in their ESFAS actuated positions. The results of the PRA concluded that these time limits would not result in a significant increase in the risk of either core damage  ;

frequency or significant radioactive release frequency. The results of the PRA also concluded that the existing cts for Actions E.1 and F.1 should be maintained in TS 3.6.3. Prior to PCN-430, TS 3.6.3 permitted the CT in -

Actions E.1 and F.1 for inoperable D.1 and D.2 valves to be in accordance with the systems in which they are installed. However, due to an oversight, j PCN-430 replaced this CT requirement with the 4-hour standardized Combustion Engineering Technical Specification CT for containment isolation valves.

Since the 4-hour CT should not apply to D.1 and D.2 valves, this license amendment is requested by Edison to restore the cts for Section D.1 and D.2 valves to the pre-Amendment 119 and 108 cts. The proposed change would eliminate.this TS inconsistency and reduce the potential for shutdown since the new TS 3.6.3 would require that the inoperable valve follow the CT of the l system in which the inoperable valve is installed. ,

l 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 l

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The proposed change is intended to ensure consistency in the application of the Completion Times (cts) for inoperable Section D.1 and D.2 containment isolation valves in Technical Specification (TS) 3.6.3 and the TS governing the system in which these valves are installed. The ,

proposed CT is consistent with the CT for these valves in the existing TSs prior to the issuance of San Onofre Unit 2 Amendment No.119 and Unit 3 Amendment No. 108 of the existing TSs. These valves were reclassified as Sections D.1 and D.2 valves and provided time limits for the period they could remain secured in their Engineered Safety Feature l Actuation Signal actuated positions.

The probability of an accident is unaffected by increasing the CT to be consistent with the CT in the TSs governing the system in which these valves are installed and the consequences of an accident are not {

affected since no physical change is made and the Safety Analysis remains unaffected. Therefore, operation of the facility in accordance {

, with this change will not involve a significant increase in the  ;

1 l probability or consequences of an accident previously evaluated. I I

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 l accident previously evaluated?

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Response: No The proposed change does not influence the possibility of a new or different accident previously evaluated because no physical change is made and the Safety Analysis is not affected. 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.

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, 3. Will operation of the facility in accordance with this proposed change .

involve a significant reduction in a margin of safety? '

Response: No l The margin of safety is unaffected since this proposed change is

consistent with the cts in the TSs governing the system in which these valves are installed. Therefore, this proposed change will not involve a significant reduction in a margin of safety.

Safety and Sionificant Hazards Determination l

Based on the above Safety Analysis, it is concluded that: 1) the proposed

! change does not constitute a significant hazards consideration as defined by l 10 CFR 50.92 and 2) there is reasonable assurance that the health and safety i 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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i ATTACHMENT "A" AMENDMENT N0. 127 APPROVED SPECIFICATIONS UNIT 2

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