ML20236J162

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Safety Evaluation Denying Util 870731 Request to Amend Licenses NPF-10 & NPF-15,consisting of Proposed Change PCN-26,to Delete Tech Spec Requirement to Rept Toxic Gas Cargo Traffic on Interstate 5.US Spill Average Has No Basis
ML20236J162
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 10/30/1987
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20236J165 List:
References
NUDOCS 8711050169
Download: ML20236J162 (1)


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. UNITED STATES 3

NUCLEAR REGULATORY COMMISSION -

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WASHINGTON, D. C. 20555

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SAFETY EVAL'UATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION z50VTHERN CALIFORhlA EDI5ON COMPANY DOCKET NOS. 50-361 AND-50-362

+r In an: attachment'to a letter dated July 31. 1987, Southern California Edison

' Company,.the licensee, submitted a proposal Technical' Specification (TS) change regardingtherequirementtosurveyperiodically(everythreeyears)the

_ hazardous cargo traffic on. Interstate 5 (I-5) near San Onofre Nuclear Generating Station (SONGS), Units 2-& 3..Specifically, in a propcsed change to the-

' Operating Licenses NPF-10 'and NPF-15 (proposed change PCN-236), TS 6.9.1.14 i

-would be revised.to remove the requirement-to monitor and report the toxic gas (cargo traffic on 1-5.

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The proposed change is based on the licensee's analysis which was submitted as

'an enclosure to the above letter. The analysis is used to demonstrate that the expected' mix of toxic substance. spills (in terms of: toxicity and quantity oilled)-is relatively' constant;with time.' Hence, the licensee concludes that ru re is-no-need for'a TS which requires a periodic' survey of the hazardous cargo. traffic on I-5 near SONGS 2 a.3.

.Our review of the.11censee's analysis indicates that there is no sound basis for concluding'that the commodity mix associated with the cargo traffic on I-5 can be expected.to be' constant for the. duration of the facility-license.

.Specifically,' thereL is no apparent evidence. that. toxic substance spill data i averaged overLthe entire United States is applicable to projecting what might happen on I-5, near' SONGS 2 & 3.

The licensee goes so far as to relate the'

-national' spill data with that of_the' State of California. Conceptually, this may

.be' reasonable, inasmuch as there may be' sufficient diversity in the geographical distribution of shipments within California so that it would be similar to nationally averaged conditions. However, we do not have any basis'for perceiving -

e similar spill data correlation between.the United States and the local traffic

. on' l-5..The apparent' constancy ~of nationally averaged spill data is understand-able..' Local shipment and accident vtriations are not observable when viewing the aggregate data for the nation. Fowever, commodity shipments at a single point are expected to De subject to fluctuations which are not necessarily the same'as the national average.

In view of the above, we do not find the proposed elimination of the TS require-ment to be justifiable on the basis of the submitted arialysis. We believe

.that the requisite data r,hould be obtained in the forthcoming traffic survey.

We note, however, that the data to be obtained, in conjunction with the previous data obtained with respect to the I-5 cargo traffic, may provide a meaningful basis for projecting the expected spill rates near the facility.

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