ML20128P344
| ML20128P344 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 10/11/1996 |
| From: | Krieger R SOUTHERN CALIFORNIA EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20128P349 | List: |
| References | |
| RTR-NUREG-1432 TAC-M86191, TAC-M86192, NUDOCS 9610170229 | |
| Download: ML20128P344 (11) | |
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SOUIHERN CAllFORNIA R. W. Krieger
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EC Vice President Nuclear Generation An LDISON INTERNATIONAL Company October 11, 1996 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C.
20555 Gentlemen:
Subject:
Docket Nos. 50-361 and 50-362 Proposed Technical Specification Change Number NPF-10/15-472 San Onofre Nuclear Generating Station l
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 Enclosed are Amendment Application Number 163 to Facility Operating License NPF-10, and Amendment Application Number 147 to Facility Operating License NPF-15, for the San Onofre Nuclear Generating Station (SONGS), Units 2 and 3.
The Amendment Applications consist of Proposed Technical Specification Change Number NPF-10/15-472 (PCN-472).
4 The proposed change is requested to reinstate provisions of the SONGS Units 2 and 3 Technical Specifications revised as part of NRC Amendment Nos.127 and 116, referenced above, for SONGS Units 2 and 3.
NRC Amendment Nos. 127 and 116 approved changes to the SONGS Units 2 and 3 Technical Specifications i
that adopted the recommendations of NUREG-1432, " Standard Technical Specifications Combustion Engineering Plants," submitted as part of Proposed Technical Specification Change Number NPF-10/15-299 (PCN-299).
The proposed change would revise the applicability of Technical Specification (TS) 3.9.6, and a note clarif Additionally, Surveillance Requirement (SR)ying LC0 3.9.6 would be included.
i 3.9.6.1 would be revised consistent with the changes to the LCO and Anplicability.
The changes described above, would reinstate provisions of the SONGS Units 2 and 3 Technical Specifications revised as par' of NRC Amendment Nos. 127 and 116.
The Southern California Edison Company requests this amendment be issued by November 30, 1996, for the start of Cycle 9 refueling outage, to be issued effective as of its date of issuance, to be implemented within 30 days from i
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P. O. Box 128 San Clemente CA 92674
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i Document Control Desk the date of issuance.
This will provide adequate time for the necessary procedure changes.
a If you would like additional information regarding this Amendment Application, l
please let me know.
Sincerely, 3
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1 Enclosure cc:
L. J. Callan, Regional Administrator, NRC Region IV J. E. Dyer, Director, Division of Reactor Projects, Region IV j
K. E. Perkins, Jr., Director, Walnut Creek Field Office, NRC Region IV
.i J. A. Sloan, NRC Senior Resident Inspector, San Onofre Units 2 & 3 j
M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3 t
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UNIIED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA EDIS0N COMPANY, ET AL. 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 163.
4 Generating Station i
SOUTHERN CALIFORNIA EDIS0N COMPANY, ET AL. pursuant to 10 CFR 50.90, hereby submit Amendment Application No 163.
This amendment application consists of Proposed Technical-Specification Change 4
No. NPF-10-472 to Facility Operating License NPF-10.
Proposed Technical Specification Change No. NPF-10-472 is a request to revise TS 3.9.6,
" Refueling Water level."
i The proposed change would revise the applicability of TS 3.9.6 and include a clarifying note.
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4 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA EDIS0N COMPANY, ET AL. for a Class 103 Docket No. 50-362 License to Acquire, Possess, and Use a Utilization Facility as Part of Amendment Application Unit No. 3 of the San Onofre Nuclear No 147.
Generating Station SOUTHERN CALIFORNIA EDISON COMPANY, ET AL. pursuant to 10 CFR 50.90, hereby submit Amendment Application No 147.
This amendment application consists of Proposed Technical Specification Change
]
No. NPF-15-472 to Facility Operating License NPF-15. Proposed Technical Specification Change No. NPF-15-472 is a request to revise TS 3.9.6,
" Refueling Water Level."
The proposed change would revise the applicability of TS 3.9.6 and include a clarifying note.
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Subscribed on this '
day of
, 1996.
Respectfully submitted, SOUTHERN CALIFORNIA EDIS0N COMPANY l
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- 1 By:
R.' W. Krieger Vice President State of California County f San Diego
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On lO \\( f d U beforeme,['(fIh41fI.hfIl sonally appeared R f d. A ff4 M /
, personally known to me -(er-provea to m&
..on--the-batis_9f_satisfa"ctory-evidence) to be the person 11Q whose name'(()
is/ ate subscribed to the within instrument and acknowledged to me that he/she/they-executed the same in his/her/4heit. authorized capacity'(TM1, and that by his/her/their signature y on the instrument the person h), or the entity upon behalf of which the personDQ acted, executed the instrument.
WITNESS my) hand and official seal.
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Subscribed on this day of b
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1996.
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Respectfully submitted, SOUTHERN CALIFORNIA EDIS0N COMPANY
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By:
Ubr R. W. Krieg'er Vice President 1
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State of California
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CountyofSafnDiego On l Ol it G(,
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orthe-bash-of-sathfaltory-evidence) to be the person'fd whose name(5{
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is/are subscribed to the within instrument and acknowledged to me that he/she/they-executed the same in his/her/their authorized capacity (ieQ, and that by his/her/-their signature (s) on the instrument the person {Q, or the entity upon behalf of which the person % acted, executed the instrument.
WITNESS my hand and official seal.
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MAAfANE SANCHEZ f
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DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-10/15-472 This is a request to revise Technical Specification (TS) 3.9.6," Refueling Water Level," for SONGS Units 2 and 3.
Existina SONGS Specifications:
Unit 2:
See Attachment "A" Unit 3:
See Attachment "B" Proposed SONGS Specifications:
Unit 2:
See Attachment "C" Unit 3:
See Attachment "D" l
Description of Chances Summary Proposed Technical Specification Change Number NPF-10/15-472 (PCN-472) addresses modifications to the Technical Specifications for the San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 approved by NRC Amendment Nos. 127 and 116. NRC Amendment Nos. 127 and 116 approved a license amendment request that adopted the recommendations of NUREG-1432, " Standard Technical Specifications Combustion Engineering Plants," requested through Proposed Technical Specification Change Number NPF-10/15-299 (PCN-299).
PCN-472 would revise TS 3.9.6, " Refueling Water Level," for SONGS Units 2 and 3.
The proposed change is required to restore certain provisions of the SONGS Units 2 and 3 operating practice that were not incorporated in PCN-299.
These changes were identified during preparation of the procedure changes necessary to implement NRC Amendment Nos. 127 and 116.
Discussion Through Proposed Technical Specification Change No. NPF-10/15-299 (PCP-299),
changes to the SONGS Uni ~ts 2 and 3 Technical Specifications were proposed that adopted the recommendations of NUREG-1432, " Standard Technical Specifications Combustion Engineering Plants."
These changes included incorporating the revised format of the NL' REG, including allowances granted by NUREG-1432, plant specific differences, and to a limited degree, changes to reflect plant specific enhancements. Mainly, the SONGS Units 2 and 3 Technical t
Specifications were directly transcribed in PCN-299. NRC Amendment Nos. 127 and 116, dated February 9,1996, approved the changes proposed through i
PCN-299.
4 Proposed Technical Specification Change Number NPF-10/15-472 (PCN-472) addresses modifications to the SONGS Units 2 and 3 Technical Specifications approved by NRC Amendment Nos. 127 and 116.
Changes are proposed that would revise TS 3.9.6, " Refueling Water Level."
The following discussion describes the proposed changes.
- The proposed change would revise TS 3.9.6, " Refueling Water Level."
TS 3.9.6 requires a minimum refueling water level of 23 feet above the reactor vessel flange, thus ensuring that the radiological consequences of a postulated fuel handling accident inside the containment, are within acceptable limits. The Specification is required during CORE ALTERATIONS, except during latching and unlatching of control rod drive shafts and during movement of irradiated fuel assemblies within containment.
Previously Specification, TS 3/4.9.10, " Water Level--Reactor Vessel,"
i similarly required that at least 23 feet of water be maintained over the top of the reactor pressure vessel flange. TS 3/4.9.10 was applicable during movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated. A footnote clarified that the water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs, coupling and uncoupling of CEA extension shafts, or for verifying the 3
coupling and uncoupling. This footnote was not included in TS 3.9.6 because it was believed to be adequately addressed, by the new words in the Applicability Statement.
The proposed change would restore the footnote because it has been determined that it is not clearly addressed by TS 3.9.6.
Specifically, a note would be added to modify LC0 3.9.6 to clearly allow that the refueling water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs, coupling and uncoupling of CEA extension shafts, or for verifying the coupling and uncoupling.
The proposed change would also revise the applicability of TS 3.9.6 to be consistent with this change.
The change would replace the portion of the applicability related to core alterations with the phrase "During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated."
This change similarly restores provisions of the existing Technical Specification.
Now, Bases 3.9.6 requires a minimum of 23 feet of water to retain 99% of 4
the total iodine released from a dropped fuel assembly, assuming that the cladding gap contains 10% of the total fuel rod iodine.
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The proposed reduction in water level to 23 feet above the fuel is considered acceptable since the fuel assemblies would be seated in the reactor vessel during CEA coupling, uncoupling, and weighing, and during removal of the four-finger CEAs. Consequently, no fuel damage could occur above the top of the fuel, and the 23 feet of water above the top of the fuel would continue to ensure that sufficient water depth is available to remove 99% of the assumed 10% iodine gap activity released from a fuel assembly damaged by any conceivable accident.
SR 3.9.6.1 would then be revised to state "The refueling water level shall be determined to be at least its minimum required depth." This change is required for consistency with the LC0.
Safety Analysis The proposed change described above shall be deemed to involve a signif' cant 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 any accident previously evaluated?
Response: No Proposed Technical Specification Change Number NPF-10/15-472 (PCN-472) addresses modifications to the Technical Specifications for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 approved by Nuclear Regulatory Commission (NRC) Amendment Nos. 127 and 116. NRC Amendment Nos. 127 and 116 approved changes to adopt the recommendations of NUREG-1432, " Standard Technical Specifications Combustion Engineering Plants," requested through Proposed Technical Specification Change Number NPF-10/15-299 (PCN-299).
The proposed changes were identified during drafting of the procedure changes required to implement NRC Amendment Nos. 127 and 116.
PCN-472 is required to restore certain provisions of the previous TSs that were not incorporated in Amendment Nos. 127 and 116.
Changes are proposed that would revise Technical Specification (TS) 3.9.6, " Refueling Water Level."
Specifically, the proposed change revises the applicability of TS 3.9.6, includes a clarifying note to TS 3.9.6, and revises Surveillance Requirement (SR) 3.9.6.1 for consistency.
The proposed reduction in water level to 23 feet above the fuel is considered acceptable since the fuel assemblies would be seated in the reactor vessel during CEA coupling, uncoupling, and weighing, and during removal of the four-finger CEAs. Consequently, no fuel damage could occur above the top of the fuel, and the 23 feet of water above the top of the fuel would continue to ensure that sufficient water depth is available to remove 99% of the assumed 10% iodine gap activity released from a fuel assembly damaged by any conceivable accident.
Operation of the facility would remain unchanged as a result of the proposed changes. Therefore, the proposed change will not involve a significant increase in the probability or consequences of any accident previously evaluated.
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2.
Will operation of the facility in accordance with this proposed 1
change create the possibility of a new or different kind of accident from any previously evaluated?
Response
No The proposed c'.ange will restore provisions of the previous TSs for SONGS Units 2 and 3.
The proposed change would revise the applicability of TS 3.9.6, include a clarifying note to TS 3.9.6, and revise SR 3.9.6.1 for consistency.
Operation of the facility would remain unchanged as a result of the proposed change.
Therefore, the 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 The proposed change will restore provisions of the previous TSs for SONGS Units 2 and 3 and make certain additional changes for clarity. Operation of the facility would remain unchanged as a result of the proposed change. Therefore, the 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..