ML13310A413

Forwards Proposed Change NPF-10-10 to Tech Specs 3.3.2, Table 3.3-5,Page 3/4 3-29.Proposed Change Enables Auxiliary Feedwater Pump Load Sequence Delay to Efas Response Time to Be Consistent W/Design Basis Requirements

ML13310A413
Person / Time
Site:	San Onofre
Issue date:	05/19/1982
From:	Baskin K Southern California Edison Co
To:	Miraglia F Office of Nuclear Reactor Regulation
Shared Package
ML13310A414	List: ML13310A413 ML20052H669
References
NUDOCS 8205210315
Download: ML13310A413 (7)

Text

REGULATOR9INFORMATION DISTRIBUTION in*TEM (RIDS)

AOSESSION NBR:8205210315 DOC.DATE:82/05/19 NOTARIZED: NO DOCKET FACIL:50-361 San Onofre Nuclear Station, Unit 2, Southern Californ 05000361 AUTH.NAME AUTHOR AFFILIATION BASKINKP. Southern California Edison Co.

RECIP.NAME RECIPIENT AFFILIATION MIRAGLIA,F. Licensing Branch 3

SUBJECT:

Forwards proposed change NPF*10-10 to Tech Specs 3.3.2, Table 3.3-5,page.3/4,3-29.Proposed change enables auxiliary feedwater pump load seouence delay to EFAS response time to be consistent w/design basis requirements.

DISTRIBUTION CODE: 80018 COPIES RECEIVED:LTR,.L ENCL - SIZE:. j.

TITLE: PSAR/FSAR AMDTS and Related Correspondence NOTES:J Hanchett icy PDR Documents. ELD Chandler Icy. 05000361 NRR Scaletti Icy.

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL A/D LICENSNG 1 0 LIC BR #3 BC 1 0 LIC BR #3 LA 1 0 ROODH. 01 1 1 INTERNAL: ELD/HDS2 1 0 IE FILE 1 1 IE/DEP EPDS 35 1 1 IE/DEP/EPLB 36 3 3 MPA 1 0 NRR/DE/CEB 11 1 1 NRR/DE/EQB 13 3 3 NRR/DE/GB 28 2 2 NRR/DE/HGEB 30 2 2 NRR/DE/MEB 18 1 1 NRR/DE/MTEB 17 1 1 NRR/DE/OAB 21 1 1 NRR/DE/SAB 24 1 1 NRR/DE/SEB 25 1 1 NRR/DHFS/HFEB40 1 .1 NRR/DHFS/LQB 32 1 1 NRR/DHFS/OLB 34 1 1 NRR/DHFS/PTR820 1 1 NRR/DSI/AEB 26 1 1 NRR/DSI/ASB 27 1 1 NRR/DSI/CPB 10 1 1 NRR/DSI/CSB 09 1 1, NRR/DSI/ETSB 12 1 .1 NRR/DSI/ICS8 16 1 1 NRR/DSI/PSB 19 1 1 NRR/DSI/RA6 22 1 1 NRR/DSI/RSB 23 1 1 NRR/DST/LGB 33 1 1 04 1 1 RGN5 2 2 EXTERNAL: ACRS 41 10 10 BNL(AMDTS ONLY) 1 1 FEMA-REP DIV 39 1 1 LPDR 03 1 1 NRC PDR 02 1 1 NSIC 05 1 1 NTIS I I NOTES: 3 3 TOTAL NUMBER OF COPIES REQUIRED: LTTR 60 ENCL 55

Southern California Edison Company P. 0. BOX 800 4

2244 WALNUT GROVE AVENUE ROSEMEAD, CALIFORNIA 91770 K. P. BASKIN TELEPHONE MANAGER OF NUCLEAR ENGINEERING, (213) 572-1401 SAFETY, AND LICENSING Director, Office of Nuclear Reactor Regulation Attention: Mr. Frank Miraglia, Branch Chief Licensing Branch No. 3 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Gentlemen:

Subject:

Docket No. 50-361 San Onofre Nuclear Generating Station Unit 2 Amendment Application No. 3 to Facility Operating License NPF-10 for San Onofre Nuclear Generating Station, Unit 2, was formally submitted NRC on May 14, 1982. Amendment Application No. 3, required prior to the to the issuance of the 5% power license, consisted of six (6) proposed changes to Technical Specifications incorporated in Facility Operating License Appendix A and one (1) proposed change to Section 2.C(5)c of FacilityNPF-10 as Operating License NPF-10.

Enclosed you will find proposed change NPF-10-10, which was formally submitted as part of Amendment Application No. 3. Changes to Technical Specification 3.3.2, Table 3.3-5 and Technical Specification 3.3.3.6, 3.3-10 are contained in NPF-10-10. It is requested that you please Table these changes to be of emergency status and direct your attention consider soon as possible. Proposed change to Technical Specification to it as 3.3-5, page 3/4 3-29 enables the AFW pump load sequence delay 3.3.2, Table time to be consistent with the design basis requirements. The to EFAS response Technical Specification, as currently written, declares the Safety Feature Actuation System to be inoperable and plant shutdown required in Mode 3.

Specification 3.3.3.6, Table 3.3-10, page 3/4 3-53, incorrectly Technical cold leg HPSI flow channels. However, the plant has 4 cold identifies 2 legs and one HPSI flow channel per cold leg. This Technical Specification, as written, is unacceptable for it limits Mode 3 operation to 7 currently desirable to alleviate this restriction. days. It is If you have any questions or if I can be of any assistance to concerning the enclosed information, please contact me. you Very truly yours, Enclosures PDR AIC~ ~801 P,

NPF-10-10 Rev. 0 DESCRIPTION OF PROPOSED CHANGE NPF-10-10 AND SAFETY ANALYSIS AMLNDMENT APPLICATION NO. 3 OPERATING LICENSE NPF-10 This is -a request to make various editorial and typoyrdpnical cnanges and resolve several inconsistencies in Appendix "A" Technical Specifications.

Existing Specifications See Attachnent "A" Proposed Specifications The proposed specifications are as follows and contained in Attachment "b" if noted:

Page 3/4 1-12 Technical Specifications 3.1.2.7.b.3 and 3.1.2.8.b.3 should be in and conformance with Tech. Spec. 3.5.4.c and therefore the upper 3/4 1-14 temperature limit should be changed from 120oF to 100 0 F.

Consistent with this reasoning, Surveillance Requirement 4.1.2.7.b and 4.1.2.8.b should read "outside air temperature is less than 40oF or greater than 100 0 F." to be in conformance with Surveillance Requirement 4.b.4.b. The more restrictive value of 100 0 F should be reflected in the Technical Specifications.

3/4 1-25 Technical Specification 3.1.3.7, contained in Attachment "B", is rewritten to allow the part length CEA.group to be withdrawn to >

145" and left full out without the necessity of withdrawing the part length CEA group to the upper electrical limit. This change will permit Specification 3.1.3.7 to be in conformance with 6 Specifications 3.1.3.4 and 3.1.3.5 which defines fully withdrawn as

> 145.

3/4 3-4 Technical Specfication 3.3.1, Table 3.3-1, notation (c) should read "bypass shall be automatically removed when THERMAL POWER is greater than or equal to 5% of RATED [HERMAL POWER" not 1%, to be consistent with the actual operation of the bistable. Table 3.3-1 ACTION 2 Line 7 reads, "Specification 6.b.1.6k" and snould read "6.b.1.6e" because parts of Section 6.5.1.6 were deleted and item "k" was relettered as item "e".

3/4 3-14 Technical Specification 3.3.2, Table 3.3-3 item 2, Containment Spray (CSAS) is required to be operable in Modes 1, 2, and 3 but not Mode 4 as defined in Technical Specification 3.6.2.1. The requirement of Mode 4 should therefore be deleted.

2 Page 3/4 3-15 Technical Specification 3.3.2, Table 3.3-3 Item b is inconsistent with the implied operability requirement Technical Specification 3.5.3 which recognizes the additional applicable Mode 4. Therefore, Mode 4 should be added to Item 5 Table 3.3-3 under Applicable Modes.

3/4 3-19 Technical Specification 3.3.2, Table 3.3-3 notation "a" should state "bypass shall be automatically removed when pressurizer pressure is greater than or equal to 400 psia", not 500 psia. This change will be consistent with FSAR Section 7.2.1.1.1.6 and Technical Specification 3.3.1, Table 3.3-1 notation "D".

3/4 3-22 Technical Specification 3.3.2, Table 3.3-4 Item Sa Manual (RAS) should be deleted. There are no manual RAS (Trip Buttuns) in the plant and therefore should be deleted. Reletter Item 5 as applicable.

3/4 3-29 Technical Specification 3.3.2, Table 3.3-5 Items 8 and 9 Auxiliary and Feedwater (AC trains), change the response time on both items from 3/4 3-30 "40.9*" to "50.9*/40.9**". The 40.9 second requirement pertains to non-LOCA events which include EDG starting in SIAS and pump load sequence delay. Such events are bounded for AFW delivery time by the loss of normal feedwater event and require AFW delivery in 42.7 seconds (40.9 is conservative). Events which require AFW when SIAS is present (e.g., small break LOCA) are bounded for AFW delivery time by the (coincident) loss of normal A/C event and -require AFW delivery in 53 seconds (50.9 is conservative). This change therefore makes the applicability of AFW pump load sequence delay to EFAS response time consistent with design basis requirements. Uue to this change the following will need to be added to the bottom of page 3/4 3-30 "** Emergency diesel generator starting delay (10 seconds) is included".

3/4 3-53 Technical Specification 3.3.3.6, Table 3.3-10, change item 23 Cold Leg HPSI Flow from 2/cold leg to 1/cold leg for the required number of channels and 1/cold leg to N.A. under minimum channels operable.

The plant has 4 cold legs and one HPSI flow channel per cold leg.

The proposed change is contained in Attachment "B".

3/4 4-3 Technical Specification 3.4.1.3 specifies:

1. With the Reactor Coolant System cold leg temperature less than or equal to 235 0 F, the SDCS isolation valves HV-9337, HV-9339, HV-9377, and HV-9378 shall be open with the SDCS relief valve PSV-9349 OPERABLE.

-3 Surveillance Requirement 4.4.8.3.1.1.a (Page 3/4 4-32).specifies:

a. Verifying at least once per 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> when the SDCS Relief Vdlve is.being used for overpressure protection that at least one pair of S0CS Relief Valve isolation VdIVES (Vdlve pair 2HV9337 and 2HV9339 or valve pair 2HV9377 and 2HV9378) is open.

The statement in Spec. 3.4.1.3 is a SURVEILLANCE REQUIREMENT contained in dn APPLICABILITY statement. This is inconsistent and redundant to Surveillance Requirement of 4.4.8.3.1.1.a and should be deleted.

3/4 4-5 Technical Specification 3.4.1.4.1, should be rewritten as "At least one shutdown cooling train shall be OPERABLE and in operation*

either:" Tne mention of suction line valves to be opened should be deleted from the first two lines. These valves are controlled by the low temperature overpressure protection Tecnnical Specification 3.4.8.3.1, ACTION item "b" which allows some of the SUCS valves to be closed at times.

3/4 4-8 Technical Specifications 4.4.3.2 should have the words "from the lE busses." added to the end of the sentence. This added information is for clarification as required by SER II.E.3.1.

3/4 4-32 Technical Specification 3.4.8.3.1 APPLICABILITY needs changed from "one any" to "any one".

3/4 7-9 Technical Specification 3.7.1.5, Modes 2 and 3, The word "in"was inadvertently omitted. It should read "Otherwise, 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 />...."

3/4 10-6 Technical Specification 3.10.5, Table 3.10-1, item 2.a Main Steam Line Area Monitor "2RT-784761" should be "2RT-7874Bl".

3/4 10-8 Technical Specification 3.10.6, line 1, the word "of" is misspelled as "fo" and requires correction.

B 3/4 7-7 Fire Suppression Systems, insert new paragraph.

"The San Onofre Unit 2&3 fire pumps and water supplies, supply water to the San Onofre Unit 1 fire system. Satisfactory completion of the Unit 2&3 fire pump and water supply surveillance requirements, automatically satisfies the Unit 1 fire water supply requirements."

This will clarify the relationship between the two fire systems.

-4 B 3/4 8-2 Surveillance Requirement 4.8.1.1.2.c requires obtaining fuel oil saimiples in accordance with ASTM-U27U-197b. As inoicated in Part 23 of the ASTM manual, the appropriate standard for ootaining these samples is ASTM-027U-196 (keveritied 197b). However key. Guide 1.137 paragraph C.2.c specifically calls for ASTM-Z70-1975.

Tnerefore, for clarity the following should be added to the end of the second paragraph of the BASES, page B 3/4 8-2: "Reg. Guide 1.137 recommends testing of fuel oil samples in accordance witn ASTM-D270-197b however ASTM-D270-1965 was reverified in 1975 and is therefore tne appropriate Standard to be used".

Reason for Proposed Change The various corrections contained in this proposed change are for clarification only.

Safety Analysis Corrections contained in this Proposed Change NPF-10-10 are editorial or typographical and do not change the intent of the Technical Specifications.

Accordingly, it is concluded that: (1) Proposed Chanye NPF-10-IU does not involve an unreviewed safety question as defined in 1U CFR 50.59, nor does it present significant hazard considerations not described or implicit in the Final Safety Analysis; (2).there is reasonable assurance that the health and safety of the public will nut be endangered by the proposed cnanye; and (4) this action will not result in a condition which significantly alters the impact of the scation on the environment as described in the NXC Final Environmental Statement.

HP:4062

NPF-10-10 ATTACHMENT A