ML20217P822

Forwards Suppl 1 to Application for Amend to Licenses NPF-10 & NPF-15,revising Containment Isolation Valves Completion Time

ML20217P822
Person / Time
Site:	San Onofre
Issue date:	04/06/1998
From:	Nunn D SOUTHERN CALIFORNIA EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217P827	List: ML20217P822 ML20217P839 ML20217P847
References
NUDOCS 9804100204
Download: ML20217P822 (3)

Text

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.[ ' d ${ l Dwight E. Nunn Vice President An wlSON IN11 %ATIO%AL Company April 6, 1998 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Gentlemen:

Subject:

Docket Nos. 50-361 and 50-362 Supplement 1 to Amendment Application Nos.158 and 142 Containment Isolation Yalves Completion Time San Onofre Nuclear Generating Station Units 2 and 3

Reference:

April 11, 1996 letter from Dwight E. Nunn (Edison) to Document Control Desk (NRC),

Subject:

Docket Nos. 50-361 and 50-362, Amendment Application Nos.158 and 142, Containment Isolation Valves Completion Time, San Onofre Nuclear Generating Station, Units 2 and 3 Enclosed are Amendment Application Nos. ISB, Supplement 1 and 142, Supplement 1 to Facility Operating Licenses NPF-10 and NPF-15 for the San Onofre Nuclear Generating Station, Units 2 and 3, respectively. The amendment applications consist of Supplement 1 to Proposed Change Number (PCN)-460.

PCN-460 is a request to revise Technical Specification (TS) 3.6.3,

" Containment Isolation Valves," to resolve an inconsistency in the TSs. '

Specifically, the Completion Times (cts) for Sections D.1 and D.2 valves are  ! 7 proposed to be revised to be in accordance with the cts for the applicable limiting condition for operation pertaining to the Engineered Safety Feature (ESF) systems in which they are installed. This inconsistency was 7 inadvertently created in Amendments 119 and 108. The proposed cts are consistent with the cts in the Units 2 and 3 TSs prior to the issuance of AmenCment Nos. 119 and 108, respectively.

The Probabilistic Risk Analysis performed for Section D.1 and D.2 valves shows that the appropriate condition for Emergency Safety Feature (ESF) system penetrations is unisolated. Therefore, TS 3.6.3, " Containment Isolation Valves," requires that Section 0.1 and 0.2 valves be secured in their P. O.Ikn 128 p San Clemente. CA 92674 0128

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Document Control Desk ' Engineered Safety Feature Actuation Signal (ESFAS) actuated position within four hours of becoming inoperable. This requirement is-intended to ensure these. valves will be able to perform their ESFAS functions.

Because the current TS requirement for Section D.1 and D.2 valves is to open these valves within four hours, the performance of on-line vcive maintenance I is precluded. This results in an increased work scope for the refueling outages and potentially extended outages. NRC approval of this license amendment request will allow Southern California Edison (SCE) to schedule on-  ;

line Motor-Operated Valve Actuator Testing (MOVAT). '

The cts for these valves in accordance with'their ESFAS function TSs are considerably longer than the four hours allowed in TS 3.6.3. To resolve this inconsistency, SCE-proposes to revise TS 3.6.3 to allow use of the appropriate j 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 LCO pertaining to the I ESF system in which it is installed." i 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 D.2 valves.

This Supplement 1 is provided in response to the San Onofre Units 2 and 3 NRC Project Manager's request. Supplement 1 provides additional information, including the results of a Probabilistic Risk Assessment. Supplement 1 also revises the requested change to clearly identify the LC0 of the ESF System in which the valve is installed, which provides the governing completion time.-

SCE's maintenance and surveillance programs for D.1 and D.2 valves require MOVAT following any wor % performed on the valve or its actuator. The MOVAT program is very intensive, and, combined with maintenance work (preventive or corrective), it takes approximately 42-52 hours per valve to complete.

'Therefore, a four-hour CT would preclude performing on-line maintenance or-surveillance testing for these valves. As indicated above, this proposed CT allowance is intended to be used during maintenance and surveillance testing aitivities on D.1 and D.2 valves. And, as has always been SCE's policy, work on these valves will be around-the-clock to ensure they are returned to operable status as soon as practicable.

4 Document Control Desk

• i SCE requests that these amendments be issted effective as of their date of issuance and be implemented within 30 days from the date of issuance. This will provide adequate time for the necessary procedure changes and training on the new TSs.

If you would like additional information on this Technical Specification change request, please let me know.

Sincerely,

,i -

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l Enclosures cc: E. W.. Merschoff, Regional Administrator, NRC 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 J W. Clifford, NRC Project Manager, San Onofre Units 2 and 3 S. Y. Hsu, Department of Health Services, Radiologic Health Branch