ML20117L054

Forwards Portions of Amends 127 & 116 LCO 3.3.11, Post Accident Monitoring Instrumentation (Pami), Implemented

ML20117L054
Person / Time
Site:	San Onofre
Issue date:	06/11/1996
From:	Marsh W SOUTHERN CALIFORNIA EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20117L059	List: ML20117L054 ML20117L061
References
RTR-REGGD-01.097, RTR-REGGD-1.097 TAC-M86191, TAC-M86192, NUDOCS 9606130196
Download: ML20117L054 (3)

Text

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Southem Califomia Edison Company P. O. BOX 128 SAN CLEMENTE, CALIFORNIA 92674-0128 WALTER C. MARSH T EL E PHONE MANAGER OF NUCLEAM REGULATORY AFFAlHS (714)368-7601 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:

Subject:

Docket Nos. 50-361 and 50-362 Implementation of Portions of Amendments 127 and 116 San Onofre Nuclear Generating Station Units 2 and 3

Reference:

Letter, Mel B. Fields (NRC) to Harold B. Ray (SCE), Subject,

" Issuance of Amendment for San Onofre Nuclear Generating Station, Unit No. 2 (TAC No. M86191) and Unit No. 3 (TAC No. M86192),"

dated, February 9, 1996 This letter is to identify that portions of Amendments 127 and 116 LC0 3.3.11

" Post Accident Monitoring Instrumentation (PAMI)" are being implemented.

Specifically, the Completion Times in restoring inoperable channels of the Containment High Range Area Monitor to operable status is being implemented.

Background

Regulatory Guide 1.97, " Instrumentation for Light-Water-Cooled Nuclear Power '

Plants to Assess Plant Environs Conditions During and Following an Accident,"

requires Licensees to have instrumentation that indicates possible gross failure of fuel cladding, or that a release may have originated -from the p(Type A instrumentation).rimary containment The Containment due toArea High Range a break inisthe reactor coolant pressur Monitor considered Type A instrumentation. In accordance with guidance provided in the new Combustion Engineering Standard Technical Specifications, NUREG-1432, Revision 0, operability requirements for this monitor are moved to LC0 3.3.11,

" Post Accident Monitoring Instrumentation (PAMI)," from LC0 3.3.3.1,

" Radiation Monitoring Instrumentation."

( Recently, problems with Containment High Range Area Monitor 2RT-7820-1 surfaced when a relatively small change in the local area temperature initiated by the fan inside containment actuated 2RT-7820-1. A special test was performed to find the dependency of 2RT-7820-1 sensitivity to the accident temperature changes associated with design basis accidents (LOCA/MSLB). The results showed that a coaxial cable which connects the RE-7820-1 detector with S

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l Document Control Desk a remote readout / alarm / control moduleis highly sensitive to the local temperature changes. The Area Radiation Monitoring System Design Bases requires the system operate for 120 days following a design basis LOCA.

The testing also revealed that moisture may travel along the cable shield into the connector, thereby shorting.out the connector. Although the SONGS -

Containment Penetration design is significantly different than the penetration configuration during testing, sufficient similarity exists to place the operability of the High Range Radiation Monitor (HRRM) in doubt.

Description of Technical Specifications j l

The existing Technical Specification, 3.3.3.1, " Radiation Monitoring

-Instrumentation," (Table 3.3-6, Actions 18,18a, and 19) requires restoration of inoperable channels to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, or be in Hot Shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Also, a Special Report should be prepared and submitted to the NRC within 14 days in accordance with TS 6.9.2.

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-The revised Technical Specification, LC0 3.3.11, approved by NRC License Amendment Nos.127 and 116, referenced above, requires inoperable channels to be restored to operable status within 30 days when one channel is inoperable.

If two channels are inoperable, the LC0 requires restoring one channel to operable status within 7 days, and if this requirement cannot be met, a Special Report should be submitted to the NRC within 30 days in accordance l

. with LC0 5.7.2. Amendments 127 and 116 were issued effective as of date of l issuance, February 9,1996, to be implemented no later than August 9,1996.

The enclosed pages provide marku)s to the existing Technical Specifications for Units 2 and 3 to implement t1e new Specification for the Containment Radiation Monitors.

Basis for Acceptability of Request There is no safety significance to early implementation of the provisions of the new Saecifications based on the following. First, it is acceptable because t1ere is no adverse interaction among the revised Specifications and other existing Technical Specification requirements. Early implementation would permit use of extended Completion Times for inoperable instruments, and avert an unnecessary plant shutdown.

Second, in accordance with the reference to this letter, the revised i' Specifications are based on NUREG-1432, an approved revised set of Standard Technical Specifications. In its review the Staff found the use of the improved Specifications acceptable for continued operation of SONGS Units 2 and 3. j By the provisions of the new specifications, alternate means of monitoring will be initiated within seven days, and if not, the plant will be shut down.

A Special Report will be submitted within the following 30 days. In addition to the provisions of 5.7.2.a, the Special Report will include discussion as to ,

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j Document Control Desk- whether the alternate means are equivalent to the installed PAMI channel, justify the areas in which they are not equivalent, and provide a schedule for restoring the normal PAMI channels.

If'you would like additional information regarding this information, please l let me know.

Sincerely, 9l&

I l Enclosure l cc: L. J. Callan, Regional Administrator, NRC Region IV i

J. E. Dyer, Director, Division of Reactor Projects, Region IV K. E. Perkins, Jr., Director, Walnut Creek Field Office, NRC Region IV J. A. Sloan, NRC Senior Resident Inspector, San Onofre Units 2 & 3 M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3 1

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