ML20198H353
| ML20198H353 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 05/16/1986 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20198H340 | List: |
| References | |
| TAC-54694, TAC-54695, TAC-54710, TAC-54711, TAC-57276, TAC-57277, NUDOCS 8605300287 | |
| Download: ML20198H353 (9) | |
Text
.
M UNITED STATES
[
g NUCLEAR REGULATORY COMMISSION 7, 7
- j WASHINGTON, D. C. 20555 t
SAFETY EVALUATION SUPPORTING ISSUANCE OF AMENDMENT NO. 46 TO NPF-10 AND AMENDMENT NO. 35 TO NPF-15 SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 & 3 4
I DOCKET NOS. 50-361 AND 50-362 INTRODUCTION Southern California Edison Company (SCE), on behalf of itself and the other j
licensees, San Diego Gas and Electric Company, The City of Riverside, California, l
and The City of Anaheim, California, has submitted several applications for license amendments for San Onofre Nuclear Generating Station (SONGS), Units 2 and 3.
Three such requests, PCN-8, 96, and 97 are evaluated herein. These proposed changes, and the NRC staff's evaluation of each, are described below.
J j
PCN-8 i
The proposed change was submitted by letter April 27, 1984 4
letter dated October 16, 1985.
It pertains to Technical Specification (TSand revised by )
3/4.6.3 " Containment Isolation Valves" and includes the Limiting Condition for Operation, Action Statements and Surveillance Requirements. As is discussed i
balow, the:NRC. staff finds-all parts of-the proposed. change acceptable with two exceptions. The exceptions are:
(1) deleting the phrase " isolation time" from LC0 3.6.3, and (2) deleting certain isolation valves associated with the secondary system from Table 3.6-1, Containment Isolation Valves.
l (A) Limiting Condition for Operation (LCO) 3.6.3 i
Proposed change PCN-8 would delete the phrase "with isolation time as shown in Table 3.6.1" from LC0 3.6.3, which previously read "The t
containment isolation valves specified in Table 3.6.1 shall be l
OPERABLE with isolation time as shown in Table 3.6-1."
The reasons i
provided by the licensee to justify the change are: (1) use of the j
term " isolation time" in the LCO implies that the LC0 is only appli-i cable to those valves for which an icolation time is specified in table 3.6-1 and (2) according to TS 4.0.3 (and its basis), OPERABILITY is based on the satisfactory completion of Surveillance Requirements.
The staff does not concur with the licensee's interpretation of the LCO, l
as stated above in item 1, namely, that operability is only associated with a valve's isolation time. On the contrary, the LCO requires
~
i 1
I
~
8605300287 860516 PDR ADOCK 05000361 P
PDR a,~
,--.--,.,_n-wn..,
w+----
-,--,w.
-,..a.-,-m-o.,v--n,e.,v-,w,-,,,w-
,---a,
,n n.y.-,--.-,e+,-,.nv
-.,w--
r.aw,.---4,..,,v-,,,--,--, -. -.,. ~
e that the containment isolation valves listed in Table 3.6-1 shall be OPERABLE and shall meet the isolation times specified.
Furthermore, the staff does not concur with rationale of item 2 since the isolation of time of a valve is not the only way to judge operability, and com-pliance with the LC0 is not confined to the time at which surveillance is performed. The staff does not find the proposed change acceptable since the meaning of valve operability has been mischaracterized and isolation time has been relegated to a minor role is. assessing continuing valve operability. Therefore, this part of PCN-8 is denied.
(B) Action statements associated with LC0 3.6.3 Proposed change PCN-8 revises the ACTION statements of LC0 3.3.3 to identify the categories of isolation valves to which existing requirements apply, i.e.
to those valves in Sections A, B and C of TS Table 3.6-1.
Section D of Table 3.6-1 has been redefined to contain only those valves which operate automati-cally on an ESFAS signal to prevent or mitigate the consequences of the design basis accident conditions. An added action statement refers the valves in Section D to the ACTION statements to the appropriate Engineered Safety Feature LC0's. The staff finds this change acceptable since it is an editorial change associated with regrouping of Table 3.6-1.
The licensee requested that an exception to the requirements of TS 3.0.4 be added to the proposed ACTION 1.d of LC0 3.6.3.
TS 3.0.4 disallows mode increases if the conditions of the LC0 are not met.
Since The ACTION state-ments of LC0 3.6.3 are not limited to any specific operating mode, upward mode changes do not relax the existing LC0 requirements.
Therefore, the staff finds the requested exception acceptable.
The proposed ACTION Statement 1.b of Technical Specification 3.6.3 deleted the word " deactivated" from the current specifications, but footnoted the word
" secured" by defining it as " locked, sealed or otherwise prevented from unintentional operation."
The reason given by the licensee is that the word
" deactivated" could be interpreted to mean that an automatic valve must be closed and deenergized, with its main circuit breaker locked open which may deenergize the position indication circuits. The proposed change will pro-vide the necessary precaution to secure the valves in the closed position from spurious or unintentional operation while maintaining the valve position indication. Therefore, the staff finds this change acceptable.
(C) Surveillance Requirements Proposed change PCN-8 deletes the word " deactivated" in Surveillance Require-ment 4.6.1.1.A, and is found acceptable by the staff on the same basis as discussed in Section B (ACTION Statements).
The licensee proposed to revise Surveillance Requirements 4.6.3.1, 4.6.3.2, and 4.6.3.3 to indicate their applicability to automatic isolation valves only, which are listed in Sections A and B of Table 3.6-1.
The proposed change adds Surveillance Requirements 4.6.3.4, and 4.6.3.5 dealing with manual valves (Section C of Table 3.6-1) and isolation valves operating on an ESFAS signal (Section D of Table 3.6-1).
The staff finds that the proposed changes to these surveillance requirements are editorial in nature resulting from the regrouping of Table 3.6-1; therefore these changes are acceptable.
(D) Table 3.6-1 (Containment Isolation Valves)
PCN-8 changes Table 3.6-1 as follows: There are four sections in this table, namely:
A. Automatic Containment Isolation, B. Containment Purge, C. Manual, D. Other. The surveillance requirements have been revised to specify the requirements of each applicable section of Table 3.6-1.
Some isolation valves have been relocated to fit into the revised group. This is an editorial change; therefore the staff finds this change acceptable. The addition of Component Cooling Water (CCW) valves to the table is acceptabJe because it reflects a design change.
Additionaly, the licensee proposes to remove valves associated with the secondary system (such as main steam isolation valves, and main feedwater isolation valves) from Table 3.6-1.
The justification provided by the licensee is:
(1)
General Design Criteria (GDC) 54 and 57 are not applicable to these secondary system isolation valves, as indicated in FSAR Table 5.2-35, and (2) some of these valves have requirements in other sec.tions of the Technical Specifications.
The staff has reviewed the proposed deletions from table 3.6-1 and has concluded that certain valves should not be deleted from the table because they are not adequately covered elsewhere in the technical specifications.
These valves are all in Section D of revised Table 3.6-1 and are designated HV-4058, HV-8202, HV-8203, HV-4053, HV-4054, and HV-4057.
Deletion of these valves as proposed by PCN-8 is hereby denied. All other valve deletions proposed by PCN-8 are acceptable, for the reasons given by the licensee.
PCN-96 l
This change was requested by letter dated November 30, 1984.
It revises Table 3.3-5 of TS 3/4.3.2, Engineered Safety Feature Actuation System (ESFAS)
Instrumentation, and TS 3/4.7.1.5, Main Steam Isolation Valves.
PCN-96 increases the Containment Spray Isolation Valve (CSIV) and Main Steam Isolation Valve (MSIV) response times specified in Table 3.3-5, and the MSIV closure time specified in TS 3/4.7.1.5.
In addition, the proposed change will revise Table 3.3-5 to:
(1)use the Containment Isolation Acutation Si and Mini-Purge Isolation Valve (MPIV) gnal (CIAS) for response time testing of MSIV and (2) exclude Component Cooling Water (CCW) valves HV-6229 and HV-6235 from the response time testing under the Safety Injection Acutation Signal (SIAS) Category.
us
6
. (A) Containment Spray Response Time Proposed Change PCN-96 increases the containment spray response time from 21 seconds to 23 seconds. This change will permit a two-second increase in the opening time of the Containment Spray Isolation Valve (CSIV) from 10 seconds to 12 seconds.
The licensee has evaluated the impact of this change, and has concluded that the increase in CSIV response time has a negligible effect on the containment response to a main steam line break with offsite power available since the analysis is bour:ded by that for a MLSB with a loss of offsite power. The consequences of a MSLB with loss of offsite power are also unaffected by the increased CSIV response time because of the emergency power load sequencing.
Valve actuation power is loaded before pump power so that by the time the pump is loaded, the valves are already fully open even with an extra two-second delay. Therefore, the limiting case for the peak containment pressure and temperature analysis, which was a MSLB with loss of offsite power, remains valid. On this basis, the staff concludes that the proposed change in containment spray response time is acceptable.
(B) MFIV, MSIV, and MPIV Response Time Testing Requirement Proposed change PCN-96 adds the response time testing requirements for for the Main Feedwater Isolation Valves (MFIV), Main Steam Isolation Valves (MSIV) and Mini-Purge Isolation Valves (MPIV) to the Containment Isolation Actuation Signal (CIAS) group.
The response time testing requirements are specified in i
Table 3.3-5, Item 3b, of the Technical Specifications. The specified response times for the MFIVs and MPIVs are 10.9, 6.9 and 5.9 seconds, respectively.
The 10.9-second and 5.9-second response times for the MFIVs and MPIVs are consistent with the existing safety analysis in the FSAR.
For MSIVs the 6.9-second closure time represents a 1 second increase over that previously prescribed. The longer MSIV response time may result in additional steam being released to the containment following a MSLB. The licensee reevaluated the steam flow through the valves during the course of valve closure, using flow area vs. time from the valve manufacturer. The net flow through the valves was determined to be less than that for the FSAR analysis. Therefore, the FSAR analysis is still valid.
Based on the above rationale, the staff finds the proposed change acceptable.
(C)
Isolation Valves HV6223 and HV6236 in the Non-critical CCW Loop Proposed change PCN-96 adds two containment isolation valves,'HV6223.and HV6236, into Note 3 of TS Table 3.3-5.
This note, referring to Item 2.(3) of TS Table 3.3-5, identifies containment isolation valves which are actuated on CIAS but not on SIAS.
These two isolation valves are train A containment
e.
. isolation valves in the non-critical Component Cooling Water (CCW) loop. The Train B isolation valves are currently included in the note. This TS change is acceptable because it reflects a design modification approved by the NRC staff in Amendment 12 to the San Onofre 2 Operating License, issued on December 23, 1982.
The basis for the staff's approval is given in the Safety Evaluation accompanying Amendment 12.
PCN-97 This change was requested by letter dated January 25, 1984.
It revises Limiting Condition for Operation (LCO) 3.6.4.1, Hydrogen Monitors, and Surveillance Requirement 4.6.4.1.
(A)
Limiting Condition for Operation 3.6.4.1 Proposed change PCN-97 adds ACTIONS b and c to Specification 3.6.4.1 as follows:
b.
With two hydroden monitors inoperable, restore at least one hydrogen monitor 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 at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
c.
With one hydrogen monitor inoperable, the provisions of Specifi-cation 3.0.4 are not applicable.
The addition of ACTION b which addresses the inoperability of two hydrogen monitors, is consistent with the ACTION requirements specified for all other accident monitoring instrumentation covered by Specification 3.3.3.6.
The staff, therefore, finds this addition acceptable. The addition of ACTION c allows for an exception from Specification 3.0.4 when one hydrogen monitor is inoperable. Without this exception, the discovery of one monitor being ' inoperable while in MODE 2 would prevent entry into MODE 1.
This is perceived to be an unnecessary restriction when compared to ACTION a which which allows continued operation for up to thirty days if a hydrogen monitor has been discovered to be inoperable immediately after entry into MODE 1.
Although the hydrogen monitors aid the operators in making decisions regarding(operation of the hydrogen recombiners, the Post Accident Sampling System PASS)isalso available to perform this function.
Therefore, we find the proposed change acceptable.
(B) Surveillance Requirement 4.6.4.1 Specification 4.6.4.1 currently requires the use of 1% and 4% concentra-I
.tions of hydrogen gas for hydrogen monitor calibration.
Proposed change PCN-97 substitutes of a 0% hydrogen gas concentration for the current 1% concentration. The manufacturer of the hygrogen monitoring system (i.e., General Electric) states that the hydrogen sensor is designed to have a linear response throughout its operational life, and is tested
e.
e for linearity.
Because of this performance characteristics, GE recommends the use of zero gas and one sample gas (e.g., 4% hydrogen concentration).
By adopting this approach, the calibration time is reduced and the length of time the containment isolation valves must be open for calibration is shortened.
The staff concurs with the licensee's rationale and finds the proposed change acceptable.
CONTACT WITH STATE OFFICIAL I
These amendments involve changes in the installation or use of facility components located within the restricted area.
The staff has determined that the amendments involve no significant increase in the amounts of any effluents that may be realease offsite and that there is no significant increase in individual or commulative occupation radiation exposure.
The Commission has previously issued proposed findings that the amendments involve no significant hazards consideration, and there has been no public comment on such findings.
Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR Sec. 51.22(c)(9).
Pursuant to 10 CRF 51.22(b) no environmental impact statement or environmental assessment need to be prepared in connection with the issuance of these amendments.
CONCLUSION Based upon our evaluation of the proposed changes to the San Onofre Units 2 and 3 Technical Specifications, we have concluded that:
there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and such activities will be conducted in compliance with the Commission's regulations hnd the issuance of the amend-ments will not inimical to the common defense and security or to the health and safety of the public.
We, therefore, conclude that the proposed-changes are acceptable, and are hereby incorporated into the San Onofre 2 and 3 Technical Specifications.
Dated:
May 16, 1986 I
e 2
I v
.p*'
UNITED STATES NUCLEAR REGULATORY COMMISSION SOUTHERN CALIFORNIA EDISON COMPANY, ET AL.
DOCKET NOS. 50-361 AND 50-362 NOTICE OF DENIAL 0F AMENDMENTS TO FACILITY OPERATING LICrNtre i99 OPPORT!!NTTY rep ppng;;;g The U. S. Nuclear Regulatory Commission (the Commission) has denied in part a request by the licensees for an amendment to Facility Operatring License Nos. NPF-10, and NPF-15 issued to the Southern California Edison Company, San Diego Gas and Electric Company, the City of Riverside, Californi,a and the City of Anaheim, California for operation of the San Onofre Nuclear Generating Station, Units 2 and 3, respectively, in San Diego County; California.
The Notice of Consideration of Issuance of Amendments was published in the Federal Register on February 12, 1986 (51 F.R. 5278).
i The amendment, as proposed by the licensees, would change the Unit 2 and 3 Technical Spe'cifications. The licensees proposed to remove valves associated with the secondary system (such as main steam isolation valves, and main feed-water isolation valves) from Table 3.6-1 of the Technical Specifications (TS).
The justification provided by the licensees is:
(1) General Design Criteria (GDC) 54 and 57 are not applicable to these secondary system isolation valves, as indicated in FSAR Table 6.2-35, and (2) some of these valves have require-ments in other sections of the Technical Specifications.
The Commission's staff finds that some of these valves are not adequately covered in other Technical Specifications. Therefore, the staff finds that the proposed change i
/
2-to remove certain isolation valves associated with the secondary system is not acceptable. Therefore, this request is denied in part.
By June 16, 1986, the licensee may demand a hearing with respect to the denial described above and any person whose interest may be affected by this proceeding may file a written petition for leave to intervene.
A request for a hearing or petition for leave to intervene must be filed with the U.S. Nuclear Regulatory Comission, Washington, D.C.
- 20555, Attentior:
Rules and Procedures Branch, Office of Administration, or may be delivered to the Commission's Public Document Room, 1717 H Street, N.W.,
I
]
Washington, D.C., by the above date.
A copy of any petitions should also be sent to the Executive Legal Director, U.S. Nuclear Regulatory Commission, Washington, D.C.
20555, and to Charles R. Kocher, Esq., Southern California Edison Company, 2244 Walnut Grove Avenue, P.O. Box 800, Rosemead, California 91770 and Orrick, Herrington and Sutcliffe, Attention:
David R. Pigott, Esq., 600 Montgomery Street, San Francisco, California 94111, attorney for the licensees.
For further details with respect to this action, see (1) the applications for amendment dated January 25, April 27, and November 30, 1984, and the supplemental letter dated October 16,1985, and (2) The Commission's Safety Evaluation issued with Amendments 46 and 35 to NPF-10 and NPF-15 dated May 16, 1986, which are available for public inspection at the Commission's Public Document Room, 1717 H Street, N.W., Washington, D.C., and at the General Library, University of California at Irvine, Irvine, California. A copy of
-.-s-3-
--r 4
m---i-
f
. Item (2) may be obtained upon request addressed to the U.S. Nuclear Regulatory Comission, Washington, D.C.
20555, Attention:
Director Division of PWR Licensing-B.
Dated at Bethesda, Maryland, this 16th day of May 1986.
FOR THE NUCLEAR REGULATORY COMMISSION George W. Knighton, Director PWR Project Directorate No. 7 Division of PWR Licensing-B'
[
[
qv ky.
r OELD[yh}%
PBD7 D:
HRood 4
G ton 4
86 4/ /86 4/llt/86
/86 i
I h#
May 16, 1986 ISSUANCE OF AMENDMENT N0.46 TO FACILITY OPERATING LICENSE NPF-10 AND AMENDMENT N0. 35 TO FACILITY OPERATING LICENSE NPF-15 SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 DISTRIBUTION Docket File 50-351/362 NRC PDR Local PDR PRC System NSIC PBD7 Reading JLee(8)
HRoad OELD LHarmon EJordan BGrimes JPartlow WJones LChandler, OELD CMiles HRDenton DGEisenhut JRutberg AToalston RDiggs, LFMB MVirigilo TBarnhart(8)
FMiraglia/FSchroeder NThcrnpson EButcher 1
f