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Suppl 2 to Applications for Amend to Licenses NPF-10 & NPF-15,revising TS 3.8.1 by Extending Offsite Circuit Completion Time from 72 Hr & 6 Days from Discovery of Failure to Meet LCO
	ML20236S622
Person / Time
Site:	San Onofre
Issue date:	07/22/1998
From:	Nunn D; SOUTHERN CALIFORNIA EDISON CO.
To:	; NRC
Shared Package
ML20236S617	List: ML20236S615; ML20236S622; ML20236S624;
References
	NUDOCS 9807270113
	Download: ML20236S622 (11)
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I UNITED STATES OF AMERICA l MCLEAR REGULATORY COMISSION l

Application of SOUTHERN CALIFORNIA Docket No. 50-361 EDISON COMPANY, EI R . for a Class 103 License to Acquire, Possess, and Use a Utilization Facility as Part of Amendment Unit No. 2 of the San Onofre Nuclear Application Generating Station No. 150, Supplement 2 SOUTHERN CALIFORNIA EDIS0N COMPANY, El E. pursuant to 10 CFR 50.90, hereby submit Amendment Application No.150, Supplement 2.

ThisamendmentapplicationconsistsofProposedChangeNumber(PCN)-453, Supplement 2, to Facility Operating License No. NPF-10. PCN-453, Supplement 2, is a request to revise Unit 2 Technical Specification (TS) 3.8.1, "AC Sources -

Operating," to 1) extend the Offsite Circuit Completion Time from "72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AE 6 days from discovery of_ failure to meet LC0" to "72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AliQ 17 days from discovery of failure to meet LC0" and 2) extend the Emergency Diesel Generator (EDG) Completion Time from "72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AlfD 6 days from discovery of failure to meet LC0" to "14 days AliQ 17 days from discovery of failure to meet LCO."

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9807270113 990722 =

PDR ADOCK 05000361!

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Subscribed on this day of C N , 1998.

Respectfullysubmitted,d SOUTHERN CALIFORNIA EDIS0N COMPANY By .

Dwight Nunn )

l Vice President I

l StateofCalifornia 1 0 efore me, b I d[N perso'nally appeared All/ C U IAlta J , persona 11y'khown to me to be the person sio fe namil is ' subscribed t'o the within instrument and j, acknowledged to me that he executed the same in his authorized capacity, i

m and that by his signature on the instrument the person, or the entity upon' ^^^^^^

behalf of which the person acted, executed the instrument. g MARIANE SANCIE WITNESSp and official seal. pg we C fones

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w UNITED. STATES OF AMERICA NUCLEAR REGULATORY COPHISSION Application of SOUTHERN CALIFORNIA Docket No. 50-362 EDIS0N COMPANY, El R. for a Class 103 License to Acquire, Possess,- and Use a Utilization Facility as Part of Amendment-Unit No. 3 of the San Onofre Nuclear Application Generating Station No. 134, Supplement 2 SOUTHERN CALIFORNIA EDIS0N COMPANY, El R. pursuant to 10 CFR 50.90, hereby submit Amendment Application No.134, Supplement 2.

This amendment application consists of Proposed Change Number (PCN)-453, Supplement 2, to facility Operating License No. NPF-15. PCN-453, Supplement 2, is a request to revise Unit 3 Technical Specification (TS) 3.8.1, "AC Sources -

Operating," to 1) extend'the Offsite Circuit Completion Time from "72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months A M 6 days from discovery of failure to meet LC0" to "72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AliQ 17 days from discovery of failure to meet LC0" and 2)' extend the Emergency Diesel Generator (EDG) Completion Time from "72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months atiQ 6 days from discovery of failure to meet LC0". to "14 days Alfa 17 days from discovery of- failure-to meet LCo."

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l Subscribedonthish day ofo i , 1998.

O Respectfully submitted, SOUTHERN CALIFORNIA EDIS0N COMI'ANY

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YL By:(DwigntNunn \ -

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VicePresident}

t State of California 0 [l h 1E V persona'lty appe'ared eforeiAme.W MutA ) , personally known to me to be the person whose nasW is subscribed to the within instrument and acknowledged to me that he executed the same in his authorized capacity, 3

and that by his signature on the instrument the person, or the entity upon behalf of which the persori acted, executed the instrument. l

'^^^^^^^^^^^^^^'

WITNES$ and and official seal.

Signature

7 l Notory PW!!c - Confomio ORANGE COUfM Comm.Ex$esOCT14,19G8 h' l

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I ENCLOSURE 1 l

l PCN-453, Supplement 2 l - J l

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l DESCRIPTION OF PROPOSED CHANGE ilPF-10/15-453, SUPPLEMENT 2 This is' a request- to revise the San Onofre Units 2 and 3 Technical l . Specification (TS) 3.8.1, "AC Sources - Operating." i Existina Specifications Unit 2: See Attachment "A" -

Unit 3: ~See Attachment "B" Prooosed Specifications with Redline and Strikeout Unit 2: See Attachment "C" Unit 3: See Attachment "D" l

Prooosed Specifications i Unit 2: See Attachment "E" i

Unit 3: See Attachment "F" DESCRIPTION OF PROPOSED CHANGES In TS 3.8.1, "AC Sources - Operating:"

o' Extend the Second Completion Time in Required Action A.2 for an l inoperable Offsite Circuit from "6 days from discovery of failure to j meet LC0" to "17 days from discovery of failure to meet LC0."

l' o Extend the Completion Time in Required Action B.4 for a single

inoperable Emergency Diesel Generator (EDG) from "72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months MQ 6 days from discovery of failure to meet LC0" to "14 days MQ 17 days from discovery of failure to meet LCO."

. Included in Attachment "C" for Unit 2 and Attachment "0" for Unit 3,

! -respectively, are revised LC0 pages 3.8-1 and 3.8-2, revised Bases pages I B3.8-6,.B3.8-9, and B3.8-29, with redline and strikeout marks. Due to text overflow, Bases pages B3.8-10 through B3.8-21 are included for completeness.

Included in Attachment "E" for Unit 2 and Attachment "F" for Unit 3, respectively, are revised LC0 and Bases pages.with redline. marks and struck-out text removed.

I BACKGROUND San Onofre Units 2 and 3 are each equipped with two seismically qualified, Class 1E, diesel engine driven generators which supply backup electrical power to the 4160 volt Class 1E busses. Each EDG is connected to the 4160 volt Class IE bus of a load group. Each EDG is designed to automatically start in the event of a bus undervoltage condition on the 4160 volt Class 1E bus to which it is connected (Loss of Voltage Signal, Sustained Degraded Voltage Signal, or Degraded Grid Voltage with SIAS Signal - LOVS/SDVS/DGVSS) or upon receipt of a Safety Injection Actuation Signal (SIAS).

Each EDG is designed to start automatically so that within 10 seconds .

following receipt of a start signal it is operating at rated voltage and speed '

and ready to begin load sequencing. The EDG is sized to supply reliable power to all safety-related loads in its respective load group, as well as specific nonsafety related loads. Loads supplied by each EDG are determined on the basis of nameplate or service factor rating, pump pressure and flow !

conditions, or pump runout conditions. Each EDG has a continuous load rating of 4700 KW. For emergency standby duty, the manufacturer allows specific overload values up to 116.1% of continuous duty rating based on the total hours the EDG is operated per year.

The design basis for standby (EDG) A. C. power is that one EDG is capable af meeting safety analysis requirements. With two available EDGs per unit, the design is capable of performing its safety function with an assumed single failure of one EDG, The design basis for the EDGs does not include any sharing of systems between Units 2 and 3. These requirements are met whether or not an extended Completion Time is allowed by the Technical Specifications (TSs).

The EDGs may be controlled or placed within their specific operating modes from the mimic bus panel in the control room or from a local panel within each EDG room. These provisions allow EDG operation for surveillance testing and manual start and load operatfor.s, as well as local operations.

The EDGs are described in Ser, tion 8.3.1 of the San Onofre Units 2 and 3 Updated Final Safety Analysis Report (UFSAR).

The current Station Blackout (SBO) analysis for San Onofre Units 2 and 3 demonstrates a 4-hour coping duration. The assumptions of the SB0 analysis regarding the availability and reliability of the EDGs are unaffected by this

proposed change. The results of the SB0 analysis are also unaffected by this j change.

DISCUSSION OF CHANGE The San Onofre Units 2 and 3 TS 3.8.1 requires if an EDG is declared inoperable for any reason, the EDG must be restored to operable status within "72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months M 6 days from discovery of failure to meet LC0" or place the plant in Hot Standby within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Cold Shutdown within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The proposed amendment would allow up to "14 days M 17 days from discovery of failure to meet LC0" to restore EDG operability. The proposed amendment also extends the Second Completion Time for an inoperable Offsite Circuit from "6 days from discovery of failure to meet LC0" to "17 days from discovery of failure to meet LC0" to be consistent with the change in the EDG Completion Time.

The Second Completion Time for the EDG and Offsite Circuit provides a limit on the maximum time allowed for any combination of required alternating current power sources to be inoperable during any single contiguous occurrence of failing to meet the Limiting Condition for Operation.

Implementation of this proposed Completion Time extension will:

o Allow increased flexibility in the scheduling and performance of preventive maintenance, o Reduce the number of individual entries into LC0 conditions by providing sufficient time to perform related maintenance tasks with a single entry.

o Allow better control of resource allocation. During outage maintenance windows, plant personnel and resources are spread across a. large number and wide variety of maintenance tasks. Allowing on-line preventive maintenance (including overhauls) gives the flexibility to focus more quality resources on any required or elected EDG maintenance.

o Avert unplanned plant shutdowns and minimize the potential for requests ,

l forNoticeofEnforcementDiscretion(N0ED). Risks ine.urred by j unexpected plant shutdowns can be comparable to and of ten exceed those ;

associated with continued power operation. '

l o Improve EDG availability during shutdown modes.

O Permit scheduling of EDG overhauls of up to 14 days on-line.

CE NPSD-996, CE0G " Joint Applications Report for Emergency Diesel Generators Completion Time Extension," provided detailed results of an integrated assessment of the overall risk associated with the adoption of the proposed i EDG Completion Time extension. This evaluation includes an assessment considering the risk associated with "at power," " transition," and " shutdown" operations and utilized Probabilistic Safety Analysis (PSA) methodology to

fully evaluate the effect of the EDG Completion Time extension. Southern California Edison (SCE) has augmented the CE NPSD-996 to include an assessment of the impact of extending the EDG Completion Time to 14 days. This information is included as Enclosure 2.

TS 5.5.2.14 " Configuration Risk Management Program," was recently )

incorporated into the TSs when the NRC issued Amendments 139.and 131 for Units 2'and 3, respectively. The purpose af the Configuration Risk Management Program (CRMP) is to ensure that a proceduralized Probabilistic Risk Assessment-informed process is in plat.c i. hat assesses the overall impact of plant maintenance on plant risk. Implementation of the CRMP will enable appropriate actions to be taken or decisions to be made to minimize and control risk when performing on-line maintenance for Systems, Structures, and Components with~ a risk-informed Completion Time. TS 5.5.2.14 will be applicable to-TS 3.8.1 because the proposed extended Completion Times for TS 3.8.1 re " risk-informed Completion Times."

During power operations, EDG preventive maintenance will not be scheduled coincident with unavailability of the same unit's turbine-driven auxiliary l

feedwater pump train due to the high risk of the configuration. In addition, during power operations, EDG preventive maintenance will not be scheduled coincident with unavailability of the same unit's opposite train EDG or safety-related equipment which receives backup power from the opposite train EDG. .These administrative controls will be governed by procedure.

~NO SIGNIFICANT HAZARDS CONSIDERATION The Commission has provided standards for determining whether a si.gnificant hazards considaa tion exists as stated in 10 CFR 50.92. A proposed amendment l to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with a proposed

' amendment would not: (1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment l' request follows:

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

Response: No The Emergency Diesel Generators (EDGs) are backup alternating current I

power sources design to power essential safety systems in the event of a

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l fully evaluate the effect of the EDG Completion Time extension. Southern California Edison (SCE) has augmented the CE NPSD-996 to include an assessment of the impact of extending the EDG Completion Time to 14 days. This information is included as Enclosure 2.

TS 5.5.2.14, " Configuration Risk Management Program," was recently incorporated into the TSs when the NRC issued Amendments 139 and 131 for Units 2 and 3, respectively. The purpose of the Configuration Risk Management Program (CRMP) is to ensure that a proceduralized Probabilistic Risk Assessment-informed process is in place that assesses the overall impact of plant maintenance on plant risk. Implementation of the CRMP will enable appropriate actions to be taken or decisions to be made to minimize and i control risk when performing on-line maintenance for Systems, Structures, and i Components with a risk-informed Completion Time. TS 5.5.2.14 will be l

applicable to TS 3.8.1 because the proposed extended Completion Times for TS l 3.8.1 are " risk-informed Completion Times."

During power operations, EDG preventive maintenance will not be scheduled coincident with unavailability of the same unit's turbine-driven auxiliary )

feedwater pump train due to the high risk of the configuration. In addition, during power operations, EDG preventive maintenance will not be scheduled ,

coincident with unavailability of the same unit's opposite train EDG or l safety-related equipment which receives backup power from the opposite train '

EDG. These administrative controls will be governed by procedure.

N0 SIGNIFICANT HAZARDS CONSIDERATION The Commission has provided standards for determining whether a significant hazards consideration exists as stated in 10 CFR 50.92. A proposed amendment to an operating license for a facility involves no significant hazards consideration if operation of the facility in accordance with a proposed amendment would not: (1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety. A discussion of these standards as they relate to this amendment request follows:

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

Response: No The Emergency Diesel Generators (EDGs) are backup alternating current j power sources design to power essential safety systems in the event of a l

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-- loss of offsite power. EDGs are not accident initiators in any accident previously evaluated., Therefore, this change does not involve an increase in the probability of an accident previously evaluated.

This proposed change will decrease the availability of the EDG in MODES

.1 ~through 4. _ This results in an increase in the probability of Station

' Blackout (SBO) from 1.6E-5 per year to 2.2E-5 per year (a difference of 6.6E-6 per year). However, the increase in the resulting at-power core damage risk is offset by the decrease in shutdown core damage' risk due to an SB0. -

' The EDGs provide backup power to components that mitigate the I

consequences of accidents. The proposed changes to the Completion Times do not affect any of the assumptions used in the deterministic safety L analysis.

To fully evaluate;the effect of the EDG Completion Time extension, l Probabilistic Safety Analysis (PSA) methods were utilized. The results l of these analyses show a reduction in the core damage frequency. As a result, there would be no significant increase in the consequences of accidents previously evaluated.

The-Configuration Risk Management Program is an Administrative Program

[ that' assesses risk based on plant status. Adding the requirement to l

implement this program for Technical Specification 3.8.1 does not affect the probability or the consequences of an accident.

iherefore, this change does nol involve a significant increase in the'

' probability or consequences of any accident previously qvaluated, i

i 2. Will operation of the facility in accordance with this proposed change l create the possibility of a new or different kind of accident from any accident previously evaluated? !

Recrmse: No This proposed change does not alter the design, configuration, or method of operation of the plant. Therefore, this change does nol create the

, possibility of a new or different kind of accident from any previously l- . evaluated.

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! 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 does not affect the Limiting Conditions for Operation or their Bases that are used in the deterministic analyses to establish the margin of safety. PSA evaluations were used to smaluate

' these changes and these evaluations determined that the changes are either risk neutral or risk beneficial.

Therefore, this change does DD1 involve a significant reduction in the !

margin of safety.

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ENVIRONMENTAL CONSIDERATION l l

SCE has determined that the proposed amendment involves no changes in the amount or type of effluent that may be released offsite, and results in no increase in individual or cumulative occupational radiation exposure. As described above, the proposed TS amendment involves no significant hazards

, consideration and, as such, meets the eligibility criteria for categorical exclusionsetforthin10CFR51.22(c)(9).

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ML20236S622

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