ML20133G906

Application for Amends to License NPF-15,requesting Rev to TSs 3.8.1.14 & 3.8.1.15, AC Sources - Operating, Surveillance Requirements

ML20133G906
Person / Time
Site:	San Onofre
Issue date:	01/14/1997
From:	Nunn D SOUTHERN CALIFORNIA EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20133G895	List: ML20133G892 ML20133G906 ML20133G910
References
RTR-NUREG-1432 NUDOCS 9701160212
Download: ML20133G906 (7)

Text

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Document Control Desk UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSIOR Application of SOUTHERN CALIFORNIA )

EDIS0N COMPANY, E R. for a Class 103 ) Docket No.

License to Acquire Possess, and Use ) 50-362 a Utilization Facility as Part of ) Amendment Unit No. 3 of the San Onofre Nuclear Application

)

Generating Station ) No 150.

SOUTHERN CALIFORNIA EDIS0N COMPANY, E R. pursuant to 10 CFR 50.90, hereby submit Amendment Application No 150.

This amendment application consists of Proposed Technical Specification Change No. 476 to Facility Operating License NPF-15. Proposed Technical Specification Change No. 476 is a request to revise TS SRs 3.8.1.14 and 3.8.1.15, "AC Sources ,

- Operating."

i The proposed change would temporarily replace SRs 3.8.1.14 and 3.8.1.15 with the SRs that had existed for this testing in the previous (pre-TSIP) TS.

Subscribed on this t day of e d dRl V , 1997.

Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY By h_ _

DwightE.Nkn Vice Presideht 9701160212 970114 PDR P

ADOCK 05000361 pyg .

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1 Document Control Desk l 1

State of California County of Sa Diego r.

On l lN D beforemedI1bkdf ll(' lf, rsonally appeared ONI AhP h M(t (U1. personally known to me (or--prmed to me -

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+% betts of satisf actory evidMto be the person (t) whose nameM isfere-tubscribedtothewithininstrumentandacknowledgedtomethat he/she/they executed the same in his/ hec /thvit authorized capacity (4es.), and that by his/her/thett signature (s), on the instrument the person (g), or the entity upon behalf of which the person (s), acted, executed the instrument.

WITNESS my hand and official seal, I j

f i-MAR!ANE SANCHEZ A, < -

Signat ureM(' Wb ; A/, COMM. # ic337a I ' 'tj . Notory Pubile - Confornia f

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j ORANGE COUNTY I_ My Comm. Expires OCT 41993 (

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DESCRIPTION AND SAFETY ANALYSIS 0F PROPOSED CHANGE 476 l l

l This is a request for an exigent Technical Specification (TS) change to revise Surveillance Requirements (SRs) 3.8.1.14 and 3.8.1.15 in TS 3.8.1, "AC Sources - ,

Operating," for SONGS Unit 3. I Existina SONGS Specifications:

Unit 3: See Attachment "A"

,P_rr2P.ffed SONGS SDecifications:

Unit 3: See Attachment "B" Description of Chanaes Summary The proposed change is requested to temporarily restore the refueling interval diesel generator surveillances as thy were prior to their revision as part of I NRC Amendment Nos. 127 and 116, for SONGS Units 2 and 3. NRC Amendment Nos. 127 and 116 approved changes to the SONGS Units 2 and 3 Technical Specifications that adopted the recommendations of NUREG-1432, " Standard Technical Specifications Combustion Engineering Plants," submitted as part of Proposed Technical Specification Change Number 299 (PCN-299) with exceptions as  ;

noted and discussed. This was performed as part of the San Onofre participation I as the lead plant for the Combustion Engineering Owners Group (CEOG) in the  !

Technical Specification Improvement Program (TSIP).

The proposed change would temporarily replace Surveillance Requirements (SRs)

SR 3.8.1.14 and 3.8.1.15 with the SRs that had existed for this testing in the previous (pre-TSIP)TS.

Discussion Through PCN-299. changes to the SONGS Units 2 and 3 Technical Specifications were d

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proposed that adopted the recommendations of NUREG-1432, " Standard Technical Specifications Combustion Engineering Plants." These changes included 1 incorporating the revised format of the NUREG, including allowances granted by NUREG-1432, plant specific differences, and to a limited degree, changes to i reflect plant specific enhancements. Mainly, the SONGS Units 2 and 3 Technical Specifications were directly transcribed in PCN-299. NRC Amendment Nos. 127 and 116, dated February 9, 1996, approved the changes propo-ad through PCN-299.

Included directly from the NUREG was the imposition of a maximum diesel generator output during the testing described in SRs 3.8.1.14 and 3.8.1.15.

The proposed change would temporarily revise, until performance of the SR to the new (post-TSIP) load limits in the next refueling outage, and prior to return to Mode 4 from the Unit 3 Cycle 9 refueling outage, the specified upper limit for generator output. The generator output of the Emergency Diesel Generator (EDG) is manually adjusted during the SRs by the operator conducting the test.

Imposing the Unit 3 NRC Amendment 116 upper limit is less severe on the equipment since this ensures the generator output is at a lower level during the test.

Consequently, there is no design consideration not being validated when the old limits are restored. However, as conducted, the previous test results did not ensure that the generator output d 4 not exceed 4700 kW during performance of these SRs, and so the new SRs were not met.

During the TSIP, Edison personnel recognized that the new TS 3.8.1 surveillances contain less rigorous kW loading limitations than were present in the corresponding pre-TSIP TS 3/4.8.1, "A.C. Sources," surveillances and incorrectly believed that the new TS surveillances were therefore satisfied. Consequently, the EDGs were tested to a more rigorous set of performance standards than allowed ,

by the new TSIP SRs. In response to a recent unrelated, but similar problem with l SR 3.8.1.9, Edison was in the process of reviewing other diesel generator l surveillances to ensure full compliance the the new TSs. During this review, on January 11, 1997, Edison recognized that the existing Unit 3 pre-TSIP l surveillances of record did not fully satisfy the new SR 3.3.1.14 and 3.8.1.15 loading requirements.

The delayed implementation until performance of the SRs to the new (post-TSIP) load limits in the next refueling outage, and prior to Mode 4 entry from the Unit 3 Cycle 9 refueling outage is requested to preclude the need to shut down the plant and unnecessarily challenge safety systems and operations. Because the Unit 3 EDGs had passed their previously required, and more rigoroas, pre-TSIP surveillances, both EDGs are fully capable of performing their safety functions.

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Document Control Desk Therefore, there would be no safety benefit in performing the post-TSIP SR, and further, there are no adverse consequences associated with not performing these SRs.

l This conclusion is corroborated by probabilistic risk assessment insights which

! indicate that deferr of the tests until the Unit 3 refueling outage would expose the plant to i.s increase in risk over that of normal plant operations and

. would avoid the risks associated with shutting the Unit down to perform these tests.

The rhange consists of adding notes to SRs 3.8.1.14 and 3.8.1.15, and restoring

the appropriate provisions from the pre-TSIP SRs. The Bases for SRs 3.8.1.14 and I 3.8.1.15 are similarly annotated to defer discussion of the post-TSIP SR output

! range until implementation of those SRs.

This change would have the effect of restoring the previous diesel generator load limit for a period until performance of the SRs to the new (post-TSIP) load limits in the next refueling outage, and prior to Mode 4 entry from the Unit 3 Cycle 9 refueling outage. After performance of the SRs to the new (post-TSIP) load limts, the TS as modified would revert to the post-TSIP Srs. This conversion to the post-TSIP SRs will occur during the Unit 3 Cycle 9 refueling outage one EDG at a time.

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 area.

1. Will operation of the facility in accordance with this proposed i change involve a significant increase in the probability or I consequences of any accident previously evaluated?

Response: No The proposed change would temporarily replace Surveillance Requirements (SRs) SR 3.8.1.14 and 3.8.1.15 with the SRs that had existed for this testing in the Technical Specifications (TSs) prior to the Technical Specification Improvement Program (TSIP).

Operation of the facility would remain unchanged as a result of the proposed changes and no assumptions or results of any accident

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Document Control Desk i analyses are affected. Therefore, the proposed change will not involve a significant increase in the probability or consequences of any accident previously evaluated.

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 previously evaluated?

Response: No I The proposed change would temporarily replace Surveillance Requirements (SRs) SR 3.8.1.14 and 3.8.1.15 with the SRs that had existed for this testing in the previous (pre-TSIP) TS.

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) 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 would temporarily replace Surveillance Requirements (SRs) SR 3.8.1.14 and 3.8.1.15 with the SRs that had existed for this testing in the previous (pre-TSIP) TS. Acceptance of the pre-TSIP test, using higher generator output, would not deleteriously impact any margin of safety. The generator output of the Emergency Diesel Generator (EDG) is manually adjusted during the SRs by the operator conducting the test. Imposing the post-TSIP upper limit is less severe on the equipment since this ensures the generator output is at a lower level during the test. Similarly, 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 Sianificant Hazards Determination Based on the above Safety Analysis, it it concluded that: (1) the proposed change does not con *titute a significant hazards consideration as defined by

l Documant Control Desk 4 10 CFR 50.92 and (2) there is reasonable assurance that the health and safety of j the public will not be endangered by the proposed change. Moreover, because this j action does not involve a significant hazards consideration, it will also not l 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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