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UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555middot0001
October 16 2012
Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 - ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be Included in the Commissions next biweekly Federal Register notice
Joseph M ebrosk Seni Project Manager Plant Licensing Brancli Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-10 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-361
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 2
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 226 license No NPF-10
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted in compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 1
-2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-10 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 226 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-10 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 226
FACILITY OPERATING LICENSE NO NPF-10
DOCKET NO 50-361
Replace the following pages of the Facility Operating License No NPF-10 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating License
REMOVE INSERT
3 3
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37middot24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 3040 and 70 to receive possess and use at any time any byproduct source and special nuclear material as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 2 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 226 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 226
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
Leo 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
---------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
A1 Enter applicable Conditions and Required Actions for affected valves of LCO 363 Containment Isolation Valvesu made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES 1 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 2 33-35 Amendment No ffi226
338 CPIS
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicableconditions and required actions of LCO 3415 uReS Leak Detect ion II
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable ---------------~------------01 Place and maintain
containment purgesupply and exhaust valves in closed pos ition
OR
021 Suspend CORE AL TERATIONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in eonta i nment
Immediately
SURVEILLANC~ REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 2 33-36 Amendment No tSr226
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
lCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES I 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES--------------------------- shy1 The provisions of lCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable 1n MODES I 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanupSystem (CREACUS) 1n isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 2 33-39 Amendment No ~226
CRIS 339
ACTIONS (continued) CONDITION REQU IRED ACTI ON COMPLETION TIME
B CRrS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
B1
OR
B21
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode i noperabl e
Place one CREACUS train in emergencymode
Suspend movement of fuel assemblies within containment
Immediately
Immediately
B22
AND
Suspend movement of fuel assemblies in the fuel storagepool
B23 --------NOTE--------shyLimited plant control operations are allowed provided the changes are accounted for in the calculated SDM
Immediately
Immediately
Suspend positivereactivity additions
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor channe1
12 hours
(continued)
SAN ONOFRE--UNIT 2 33-40 Amendment No +15226
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCO 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES I 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicable when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inoperable due to inoperable CRE boundary in Modes 1 2 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant exposures to radiologicalchemical and smoke hazards will not exceed limits
Restore eRE boundary to OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 2 37-24 Amendment No m226
CREACUS 3711
ACTIONS (continued)
CONDITION
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1 2 3 or 4
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
C 1 Be in MODE 3
AND
C2 Be in MODE 5
D1
OR
021
AND
D22
AND
D23
Place OPERABLE CREACUS train in emergency radiation protection mode
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
6 hours
36 hours
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 37-25 Amendment No rt4226
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
E Two CREACUS trains inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E1 Suspend CORE ALTERATIONS
AND
E2 Suspend movement of fuel assemblies within containment
AND
Immediately
Immediately
One or more CREACUS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E3 Suspend movement of fuel assemblies in the fuel storage pool
Immediately
(continued)
SAN ONOFRE--UNIT 2 37-25a Amendment Nolt4226
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCD 3716 The fuel storage pool water level shall be pound 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage poolwater level not within 1imit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is ~ 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 2 37-29 Amendment No irJ226
AC Sources - Shutdown 382
3B ELECTRICAL POWER SYSTEMS
382 AC Sources-Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualified circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3810 Distribution Systems Shutdown and
b One diesel generator (OG) capable of supplying one train of the onsite Class IE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCO 3B10 with one requiredtrain de-energized as a result of Condition A
A Declare affected required feature(s) with no offsite poweravailable inoperfrble
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-17 Amendment No frr226
AC Sources - Shutdown 382
ACTIONS
CONDITION REQU IRED ACTI ON COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-18 Amendment No +r5226
AC Sources - ShlJtdown 382
CONDITION REQUIRED ACTION COMPLETION TIME
B One required DG inoperable
B1
AND
B2
AND
B3
AND
B4
AND
B5
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Initiate action to restore required DG to OPERABLE status
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 38-18a Amendment No 226
DC Sources - Shutdown 3B5
3B ELECTRICAL POWER SYSTEMS
3B5 DC Sources Shutdown
LCO 385 The DC e1ectrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3B10 Distribution Systems - Shutdown
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------shyLCO 303 is not applicable
CONDITION
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
---------------------shyOne or two requiredbattery charger(s) on one train inoperable
REQUIRED ACTION
AI Restore battery terminal voltage to greater than or equal to the minimum estatilished float voltage
AND A2 Verify battery float
current ~ 150 amps
AND
A31
QR
Restore required battery charger(s) to OPERABLE status bull
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s) to OPERABLE status
COMPLETION TIME
2 hours
Once per 12 hours
72 hOlirs
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 2 38-27 Amendment No rtS226
DC Sources - Shutdown 385
CONDITION REQUIRED ACTION
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
D1 Declare affected reguired feature(s) inoperable
ill D21 Sus~end CORE
ALT RATIONS
AND
022 sus~end movement of fue assemblies within containment
AND
023 Sus~end movement of fue assemblies in the fuel storagepool
AND
024 Suspend operationsinvo1vin positivereactivi y additions r that could result in loss of required SDM or boron concentration
AND
025 Initiate action to restore required DC electrical )owerSUbs~stem(s to OPER BLE status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
IITIOediate1y
Immediately
SAN ONOFRE--UNIT 2 38-28 Amendment No e+8226
Inverters - Shutdown 38B
38 ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 388 Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s required by LCO 3810 Distribution Sys terns - Shutdown II
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQU I RED ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1 Declare affected required feature(s) inoperable
OR
A2l Suspend CORE ALTERATIONS
Immediately
Immediately
A22 Suspend movement of fuel assemblies within containment
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storagepool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-36 Amendment No f15226
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-361
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 2
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 226 license No NPF-10
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted in compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 1
-2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-10 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 226 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-10 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 226
FACILITY OPERATING LICENSE NO NPF-10
DOCKET NO 50-361
Replace the following pages of the Facility Operating License No NPF-10 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating License
REMOVE INSERT
3 3
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37middot24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 3040 and 70 to receive possess and use at any time any byproduct source and special nuclear material as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 2 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 226 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 226
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
Leo 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
---------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
A1 Enter applicable Conditions and Required Actions for affected valves of LCO 363 Containment Isolation Valvesu made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES 1 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 2 33-35 Amendment No ffi226
338 CPIS
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicableconditions and required actions of LCO 3415 uReS Leak Detect ion II
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable ---------------~------------01 Place and maintain
containment purgesupply and exhaust valves in closed pos ition
OR
021 Suspend CORE AL TERATIONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in eonta i nment
Immediately
SURVEILLANC~ REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 2 33-36 Amendment No tSr226
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
lCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES I 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES--------------------------- shy1 The provisions of lCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable 1n MODES I 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanupSystem (CREACUS) 1n isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 2 33-39 Amendment No ~226
CRIS 339
ACTIONS (continued) CONDITION REQU IRED ACTI ON COMPLETION TIME
B CRrS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
B1
OR
B21
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode i noperabl e
Place one CREACUS train in emergencymode
Suspend movement of fuel assemblies within containment
Immediately
Immediately
B22
AND
Suspend movement of fuel assemblies in the fuel storagepool
B23 --------NOTE--------shyLimited plant control operations are allowed provided the changes are accounted for in the calculated SDM
Immediately
Immediately
Suspend positivereactivity additions
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor channe1
12 hours
(continued)
SAN ONOFRE--UNIT 2 33-40 Amendment No +15226
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCO 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES I 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicable when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inoperable due to inoperable CRE boundary in Modes 1 2 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant exposures to radiologicalchemical and smoke hazards will not exceed limits
Restore eRE boundary to OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 2 37-24 Amendment No m226
CREACUS 3711
ACTIONS (continued)
CONDITION
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1 2 3 or 4
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
C 1 Be in MODE 3
AND
C2 Be in MODE 5
D1
OR
021
AND
D22
AND
D23
Place OPERABLE CREACUS train in emergency radiation protection mode
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
6 hours
36 hours
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 37-25 Amendment No rt4226
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
E Two CREACUS trains inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E1 Suspend CORE ALTERATIONS
AND
E2 Suspend movement of fuel assemblies within containment
AND
Immediately
Immediately
One or more CREACUS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E3 Suspend movement of fuel assemblies in the fuel storage pool
Immediately
(continued)
SAN ONOFRE--UNIT 2 37-25a Amendment Nolt4226
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCD 3716 The fuel storage pool water level shall be pound 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage poolwater level not within 1imit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is ~ 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 2 37-29 Amendment No irJ226
AC Sources - Shutdown 382
3B ELECTRICAL POWER SYSTEMS
382 AC Sources-Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualified circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3810 Distribution Systems Shutdown and
b One diesel generator (OG) capable of supplying one train of the onsite Class IE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCO 3B10 with one requiredtrain de-energized as a result of Condition A
A Declare affected required feature(s) with no offsite poweravailable inoperfrble
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-17 Amendment No frr226
AC Sources - Shutdown 382
ACTIONS
CONDITION REQU IRED ACTI ON COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-18 Amendment No +r5226
AC Sources - ShlJtdown 382
CONDITION REQUIRED ACTION COMPLETION TIME
B One required DG inoperable
B1
AND
B2
AND
B3
AND
B4
AND
B5
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Initiate action to restore required DG to OPERABLE status
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 38-18a Amendment No 226
DC Sources - Shutdown 3B5
3B ELECTRICAL POWER SYSTEMS
3B5 DC Sources Shutdown
LCO 385 The DC e1ectrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3B10 Distribution Systems - Shutdown
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------shyLCO 303 is not applicable
CONDITION
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
---------------------shyOne or two requiredbattery charger(s) on one train inoperable
REQUIRED ACTION
AI Restore battery terminal voltage to greater than or equal to the minimum estatilished float voltage
AND A2 Verify battery float
current ~ 150 amps
AND
A31
QR
Restore required battery charger(s) to OPERABLE status bull
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s) to OPERABLE status
COMPLETION TIME
2 hours
Once per 12 hours
72 hOlirs
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 2 38-27 Amendment No rtS226
DC Sources - Shutdown 385
CONDITION REQUIRED ACTION
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
D1 Declare affected reguired feature(s) inoperable
ill D21 Sus~end CORE
ALT RATIONS
AND
022 sus~end movement of fue assemblies within containment
AND
023 Sus~end movement of fue assemblies in the fuel storagepool
AND
024 Suspend operationsinvo1vin positivereactivi y additions r that could result in loss of required SDM or boron concentration
AND
025 Initiate action to restore required DC electrical )owerSUbs~stem(s to OPER BLE status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
IITIOediate1y
Immediately
SAN ONOFRE--UNIT 2 38-28 Amendment No e+8226
Inverters - Shutdown 38B
38 ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 388 Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s required by LCO 3810 Distribution Sys terns - Shutdown II
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQU I RED ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1 Declare affected required feature(s) inoperable
OR
A2l Suspend CORE ALTERATIONS
Immediately
Immediately
A22 Suspend movement of fuel assemblies within containment
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storagepool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-36 Amendment No f15226
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
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4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
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bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
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bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
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D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
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Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
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assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
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TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
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Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
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containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
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Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
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Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
-2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-10 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 226 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of its date of issuance and shall be implemented within 60 days from the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-10 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 226
FACILITY OPERATING LICENSE NO NPF-10
DOCKET NO 50-361
Replace the following pages of the Facility Operating License No NPF-10 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating License
REMOVE INSERT
3 3
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37middot24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 3040 and 70 to receive possess and use at any time any byproduct source and special nuclear material as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 2 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 226 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 226
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
Leo 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
---------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
A1 Enter applicable Conditions and Required Actions for affected valves of LCO 363 Containment Isolation Valvesu made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES 1 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 2 33-35 Amendment No ffi226
338 CPIS
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicableconditions and required actions of LCO 3415 uReS Leak Detect ion II
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable ---------------~------------01 Place and maintain
containment purgesupply and exhaust valves in closed pos ition
OR
021 Suspend CORE AL TERATIONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in eonta i nment
Immediately
SURVEILLANC~ REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 2 33-36 Amendment No tSr226
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
lCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES I 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES--------------------------- shy1 The provisions of lCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable 1n MODES I 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanupSystem (CREACUS) 1n isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 2 33-39 Amendment No ~226
CRIS 339
ACTIONS (continued) CONDITION REQU IRED ACTI ON COMPLETION TIME
B CRrS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
B1
OR
B21
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode i noperabl e
Place one CREACUS train in emergencymode
Suspend movement of fuel assemblies within containment
Immediately
Immediately
B22
AND
Suspend movement of fuel assemblies in the fuel storagepool
B23 --------NOTE--------shyLimited plant control operations are allowed provided the changes are accounted for in the calculated SDM
Immediately
Immediately
Suspend positivereactivity additions
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor channe1
12 hours
(continued)
SAN ONOFRE--UNIT 2 33-40 Amendment No +15226
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCO 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES I 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicable when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inoperable due to inoperable CRE boundary in Modes 1 2 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant exposures to radiologicalchemical and smoke hazards will not exceed limits
Restore eRE boundary to OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 2 37-24 Amendment No m226
CREACUS 3711
ACTIONS (continued)
CONDITION
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1 2 3 or 4
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
C 1 Be in MODE 3
AND
C2 Be in MODE 5
D1
OR
021
AND
D22
AND
D23
Place OPERABLE CREACUS train in emergency radiation protection mode
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
6 hours
36 hours
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 37-25 Amendment No rt4226
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
E Two CREACUS trains inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E1 Suspend CORE ALTERATIONS
AND
E2 Suspend movement of fuel assemblies within containment
AND
Immediately
Immediately
One or more CREACUS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E3 Suspend movement of fuel assemblies in the fuel storage pool
Immediately
(continued)
SAN ONOFRE--UNIT 2 37-25a Amendment Nolt4226
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCD 3716 The fuel storage pool water level shall be pound 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage poolwater level not within 1imit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is ~ 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 2 37-29 Amendment No irJ226
AC Sources - Shutdown 382
3B ELECTRICAL POWER SYSTEMS
382 AC Sources-Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualified circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3810 Distribution Systems Shutdown and
b One diesel generator (OG) capable of supplying one train of the onsite Class IE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCO 3B10 with one requiredtrain de-energized as a result of Condition A
A Declare affected required feature(s) with no offsite poweravailable inoperfrble
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-17 Amendment No frr226
AC Sources - Shutdown 382
ACTIONS
CONDITION REQU IRED ACTI ON COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-18 Amendment No +r5226
AC Sources - ShlJtdown 382
CONDITION REQUIRED ACTION COMPLETION TIME
B One required DG inoperable
B1
AND
B2
AND
B3
AND
B4
AND
B5
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Initiate action to restore required DG to OPERABLE status
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 38-18a Amendment No 226
DC Sources - Shutdown 3B5
3B ELECTRICAL POWER SYSTEMS
3B5 DC Sources Shutdown
LCO 385 The DC e1ectrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3B10 Distribution Systems - Shutdown
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------shyLCO 303 is not applicable
CONDITION
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
---------------------shyOne or two requiredbattery charger(s) on one train inoperable
REQUIRED ACTION
AI Restore battery terminal voltage to greater than or equal to the minimum estatilished float voltage
AND A2 Verify battery float
current ~ 150 amps
AND
A31
QR
Restore required battery charger(s) to OPERABLE status bull
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s) to OPERABLE status
COMPLETION TIME
2 hours
Once per 12 hours
72 hOlirs
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 2 38-27 Amendment No rtS226
DC Sources - Shutdown 385
CONDITION REQUIRED ACTION
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
D1 Declare affected reguired feature(s) inoperable
ill D21 Sus~end CORE
ALT RATIONS
AND
022 sus~end movement of fue assemblies within containment
AND
023 Sus~end movement of fue assemblies in the fuel storagepool
AND
024 Suspend operationsinvo1vin positivereactivi y additions r that could result in loss of required SDM or boron concentration
AND
025 Initiate action to restore required DC electrical )owerSUbs~stem(s to OPER BLE status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
IITIOediate1y
Immediately
SAN ONOFRE--UNIT 2 38-28 Amendment No e+8226
Inverters - Shutdown 38B
38 ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 388 Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s required by LCO 3810 Distribution Sys terns - Shutdown II
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQU I RED ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1 Declare affected required feature(s) inoperable
OR
A2l Suspend CORE ALTERATIONS
Immediately
Immediately
A22 Suspend movement of fuel assemblies within containment
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storagepool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-36 Amendment No f15226
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
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ADAMS Accession No ML12215A399 OFFICE
NAME
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PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
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NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
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DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
ATTACHMENT TO LICENSE AMENDMENT NO 226
FACILITY OPERATING LICENSE NO NPF-10
DOCKET NO 50-361
Replace the following pages of the Facility Operating License No NPF-10 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating License
REMOVE INSERT
3 3
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37middot24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
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(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 3040 and 70 to receive possess and use at any time any byproduct source and special nuclear material as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 2 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 226 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 226
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
Leo 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
---------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
A1 Enter applicable Conditions and Required Actions for affected valves of LCO 363 Containment Isolation Valvesu made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES 1 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 2 33-35 Amendment No ffi226
338 CPIS
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicableconditions and required actions of LCO 3415 uReS Leak Detect ion II
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable ---------------~------------01 Place and maintain
containment purgesupply and exhaust valves in closed pos ition
OR
021 Suspend CORE AL TERATIONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in eonta i nment
Immediately
SURVEILLANC~ REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 2 33-36 Amendment No tSr226
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
lCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES I 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES--------------------------- shy1 The provisions of lCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable 1n MODES I 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanupSystem (CREACUS) 1n isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 2 33-39 Amendment No ~226
CRIS 339
ACTIONS (continued) CONDITION REQU IRED ACTI ON COMPLETION TIME
B CRrS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
B1
OR
B21
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode i noperabl e
Place one CREACUS train in emergencymode
Suspend movement of fuel assemblies within containment
Immediately
Immediately
B22
AND
Suspend movement of fuel assemblies in the fuel storagepool
B23 --------NOTE--------shyLimited plant control operations are allowed provided the changes are accounted for in the calculated SDM
Immediately
Immediately
Suspend positivereactivity additions
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor channe1
12 hours
(continued)
SAN ONOFRE--UNIT 2 33-40 Amendment No +15226
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCO 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES I 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicable when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inoperable due to inoperable CRE boundary in Modes 1 2 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant exposures to radiologicalchemical and smoke hazards will not exceed limits
Restore eRE boundary to OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 2 37-24 Amendment No m226
CREACUS 3711
ACTIONS (continued)
CONDITION
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1 2 3 or 4
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
C 1 Be in MODE 3
AND
C2 Be in MODE 5
D1
OR
021
AND
D22
AND
D23
Place OPERABLE CREACUS train in emergency radiation protection mode
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
6 hours
36 hours
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 37-25 Amendment No rt4226
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
E Two CREACUS trains inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E1 Suspend CORE ALTERATIONS
AND
E2 Suspend movement of fuel assemblies within containment
AND
Immediately
Immediately
One or more CREACUS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E3 Suspend movement of fuel assemblies in the fuel storage pool
Immediately
(continued)
SAN ONOFRE--UNIT 2 37-25a Amendment Nolt4226
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCD 3716 The fuel storage pool water level shall be pound 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage poolwater level not within 1imit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is ~ 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 2 37-29 Amendment No irJ226
AC Sources - Shutdown 382
3B ELECTRICAL POWER SYSTEMS
382 AC Sources-Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualified circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3810 Distribution Systems Shutdown and
b One diesel generator (OG) capable of supplying one train of the onsite Class IE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCO 3B10 with one requiredtrain de-energized as a result of Condition A
A Declare affected required feature(s) with no offsite poweravailable inoperfrble
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-17 Amendment No frr226
AC Sources - Shutdown 382
ACTIONS
CONDITION REQU IRED ACTI ON COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-18 Amendment No +r5226
AC Sources - ShlJtdown 382
CONDITION REQUIRED ACTION COMPLETION TIME
B One required DG inoperable
B1
AND
B2
AND
B3
AND
B4
AND
B5
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Initiate action to restore required DG to OPERABLE status
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 38-18a Amendment No 226
DC Sources - Shutdown 3B5
3B ELECTRICAL POWER SYSTEMS
3B5 DC Sources Shutdown
LCO 385 The DC e1ectrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3B10 Distribution Systems - Shutdown
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------shyLCO 303 is not applicable
CONDITION
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
---------------------shyOne or two requiredbattery charger(s) on one train inoperable
REQUIRED ACTION
AI Restore battery terminal voltage to greater than or equal to the minimum estatilished float voltage
AND A2 Verify battery float
current ~ 150 amps
AND
A31
QR
Restore required battery charger(s) to OPERABLE status bull
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s) to OPERABLE status
COMPLETION TIME
2 hours
Once per 12 hours
72 hOlirs
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 2 38-27 Amendment No rtS226
DC Sources - Shutdown 385
CONDITION REQUIRED ACTION
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
D1 Declare affected reguired feature(s) inoperable
ill D21 Sus~end CORE
ALT RATIONS
AND
022 sus~end movement of fue assemblies within containment
AND
023 Sus~end movement of fue assemblies in the fuel storagepool
AND
024 Suspend operationsinvo1vin positivereactivi y additions r that could result in loss of required SDM or boron concentration
AND
025 Initiate action to restore required DC electrical )owerSUbs~stem(s to OPER BLE status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
IITIOediate1y
Immediately
SAN ONOFRE--UNIT 2 38-28 Amendment No e+8226
Inverters - Shutdown 38B
38 ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 388 Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s required by LCO 3810 Distribution Sys terns - Shutdown II
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQU I RED ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1 Declare affected required feature(s) inoperable
OR
A2l Suspend CORE ALTERATIONS
Immediately
Immediately
A22 Suspend movement of fuel assemblies within containment
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storagepool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-36 Amendment No f15226
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 3040 and 70 to receive possess and use at any time any byproduct source and special nuclear material as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 2 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 226 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 226
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
Leo 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
---------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
A1 Enter applicable Conditions and Required Actions for affected valves of LCO 363 Containment Isolation Valvesu made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES 1 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 2 33-35 Amendment No ffi226
338 CPIS
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicableconditions and required actions of LCO 3415 uReS Leak Detect ion II
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable ---------------~------------01 Place and maintain
containment purgesupply and exhaust valves in closed pos ition
OR
021 Suspend CORE AL TERATIONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in eonta i nment
Immediately
SURVEILLANC~ REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 2 33-36 Amendment No tSr226
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
lCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES I 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES--------------------------- shy1 The provisions of lCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable 1n MODES I 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanupSystem (CREACUS) 1n isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 2 33-39 Amendment No ~226
CRIS 339
ACTIONS (continued) CONDITION REQU IRED ACTI ON COMPLETION TIME
B CRrS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
B1
OR
B21
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode i noperabl e
Place one CREACUS train in emergencymode
Suspend movement of fuel assemblies within containment
Immediately
Immediately
B22
AND
Suspend movement of fuel assemblies in the fuel storagepool
B23 --------NOTE--------shyLimited plant control operations are allowed provided the changes are accounted for in the calculated SDM
Immediately
Immediately
Suspend positivereactivity additions
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor channe1
12 hours
(continued)
SAN ONOFRE--UNIT 2 33-40 Amendment No +15226
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCO 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES I 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicable when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inoperable due to inoperable CRE boundary in Modes 1 2 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant exposures to radiologicalchemical and smoke hazards will not exceed limits
Restore eRE boundary to OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 2 37-24 Amendment No m226
CREACUS 3711
ACTIONS (continued)
CONDITION
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1 2 3 or 4
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
C 1 Be in MODE 3
AND
C2 Be in MODE 5
D1
OR
021
AND
D22
AND
D23
Place OPERABLE CREACUS train in emergency radiation protection mode
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
6 hours
36 hours
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 37-25 Amendment No rt4226
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
E Two CREACUS trains inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E1 Suspend CORE ALTERATIONS
AND
E2 Suspend movement of fuel assemblies within containment
AND
Immediately
Immediately
One or more CREACUS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E3 Suspend movement of fuel assemblies in the fuel storage pool
Immediately
(continued)
SAN ONOFRE--UNIT 2 37-25a Amendment Nolt4226
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCD 3716 The fuel storage pool water level shall be pound 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage poolwater level not within 1imit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is ~ 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 2 37-29 Amendment No irJ226
AC Sources - Shutdown 382
3B ELECTRICAL POWER SYSTEMS
382 AC Sources-Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualified circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3810 Distribution Systems Shutdown and
b One diesel generator (OG) capable of supplying one train of the onsite Class IE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCO 3B10 with one requiredtrain de-energized as a result of Condition A
A Declare affected required feature(s) with no offsite poweravailable inoperfrble
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-17 Amendment No frr226
AC Sources - Shutdown 382
ACTIONS
CONDITION REQU IRED ACTI ON COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-18 Amendment No +r5226
AC Sources - ShlJtdown 382
CONDITION REQUIRED ACTION COMPLETION TIME
B One required DG inoperable
B1
AND
B2
AND
B3
AND
B4
AND
B5
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Initiate action to restore required DG to OPERABLE status
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 38-18a Amendment No 226
DC Sources - Shutdown 3B5
3B ELECTRICAL POWER SYSTEMS
3B5 DC Sources Shutdown
LCO 385 The DC e1ectrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3B10 Distribution Systems - Shutdown
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------shyLCO 303 is not applicable
CONDITION
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
---------------------shyOne or two requiredbattery charger(s) on one train inoperable
REQUIRED ACTION
AI Restore battery terminal voltage to greater than or equal to the minimum estatilished float voltage
AND A2 Verify battery float
current ~ 150 amps
AND
A31
QR
Restore required battery charger(s) to OPERABLE status bull
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s) to OPERABLE status
COMPLETION TIME
2 hours
Once per 12 hours
72 hOlirs
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 2 38-27 Amendment No rtS226
DC Sources - Shutdown 385
CONDITION REQUIRED ACTION
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
D1 Declare affected reguired feature(s) inoperable
ill D21 Sus~end CORE
ALT RATIONS
AND
022 sus~end movement of fue assemblies within containment
AND
023 Sus~end movement of fue assemblies in the fuel storagepool
AND
024 Suspend operationsinvo1vin positivereactivi y additions r that could result in loss of required SDM or boron concentration
AND
025 Initiate action to restore required DC electrical )owerSUbs~stem(s to OPER BLE status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
IITIOediate1y
Immediately
SAN ONOFRE--UNIT 2 38-28 Amendment No e+8226
Inverters - Shutdown 38B
38 ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 388 Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s required by LCO 3810 Distribution Sys terns - Shutdown II
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQU I RED ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1 Declare affected required feature(s) inoperable
OR
A2l Suspend CORE ALTERATIONS
Immediately
Immediately
A22 Suspend movement of fuel assemblies within containment
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storagepool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-36 Amendment No f15226
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
Leo 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
---------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
A1 Enter applicable Conditions and Required Actions for affected valves of LCO 363 Containment Isolation Valvesu made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES 1 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 2 33-35 Amendment No ffi226
338 CPIS
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicableconditions and required actions of LCO 3415 uReS Leak Detect ion II
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable ---------------~------------01 Place and maintain
containment purgesupply and exhaust valves in closed pos ition
OR
021 Suspend CORE AL TERATIONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in eonta i nment
Immediately
SURVEILLANC~ REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 2 33-36 Amendment No tSr226
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
lCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES I 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES--------------------------- shy1 The provisions of lCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable 1n MODES I 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanupSystem (CREACUS) 1n isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 2 33-39 Amendment No ~226
CRIS 339
ACTIONS (continued) CONDITION REQU IRED ACTI ON COMPLETION TIME
B CRrS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
B1
OR
B21
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode i noperabl e
Place one CREACUS train in emergencymode
Suspend movement of fuel assemblies within containment
Immediately
Immediately
B22
AND
Suspend movement of fuel assemblies in the fuel storagepool
B23 --------NOTE--------shyLimited plant control operations are allowed provided the changes are accounted for in the calculated SDM
Immediately
Immediately
Suspend positivereactivity additions
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor channe1
12 hours
(continued)
SAN ONOFRE--UNIT 2 33-40 Amendment No +15226
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCO 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES I 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicable when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inoperable due to inoperable CRE boundary in Modes 1 2 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant exposures to radiologicalchemical and smoke hazards will not exceed limits
Restore eRE boundary to OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 2 37-24 Amendment No m226
CREACUS 3711
ACTIONS (continued)
CONDITION
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1 2 3 or 4
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
C 1 Be in MODE 3
AND
C2 Be in MODE 5
D1
OR
021
AND
D22
AND
D23
Place OPERABLE CREACUS train in emergency radiation protection mode
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
6 hours
36 hours
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 37-25 Amendment No rt4226
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
E Two CREACUS trains inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E1 Suspend CORE ALTERATIONS
AND
E2 Suspend movement of fuel assemblies within containment
AND
Immediately
Immediately
One or more CREACUS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E3 Suspend movement of fuel assemblies in the fuel storage pool
Immediately
(continued)
SAN ONOFRE--UNIT 2 37-25a Amendment Nolt4226
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCD 3716 The fuel storage pool water level shall be pound 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage poolwater level not within 1imit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is ~ 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 2 37-29 Amendment No irJ226
AC Sources - Shutdown 382
3B ELECTRICAL POWER SYSTEMS
382 AC Sources-Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualified circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3810 Distribution Systems Shutdown and
b One diesel generator (OG) capable of supplying one train of the onsite Class IE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCO 3B10 with one requiredtrain de-energized as a result of Condition A
A Declare affected required feature(s) with no offsite poweravailable inoperfrble
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-17 Amendment No frr226
AC Sources - Shutdown 382
ACTIONS
CONDITION REQU IRED ACTI ON COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-18 Amendment No +r5226
AC Sources - ShlJtdown 382
CONDITION REQUIRED ACTION COMPLETION TIME
B One required DG inoperable
B1
AND
B2
AND
B3
AND
B4
AND
B5
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Initiate action to restore required DG to OPERABLE status
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 38-18a Amendment No 226
DC Sources - Shutdown 3B5
3B ELECTRICAL POWER SYSTEMS
3B5 DC Sources Shutdown
LCO 385 The DC e1ectrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3B10 Distribution Systems - Shutdown
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------shyLCO 303 is not applicable
CONDITION
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
---------------------shyOne or two requiredbattery charger(s) on one train inoperable
REQUIRED ACTION
AI Restore battery terminal voltage to greater than or equal to the minimum estatilished float voltage
AND A2 Verify battery float
current ~ 150 amps
AND
A31
QR
Restore required battery charger(s) to OPERABLE status bull
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s) to OPERABLE status
COMPLETION TIME
2 hours
Once per 12 hours
72 hOlirs
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 2 38-27 Amendment No rtS226
DC Sources - Shutdown 385
CONDITION REQUIRED ACTION
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
D1 Declare affected reguired feature(s) inoperable
ill D21 Sus~end CORE
ALT RATIONS
AND
022 sus~end movement of fue assemblies within containment
AND
023 Sus~end movement of fue assemblies in the fuel storagepool
AND
024 Suspend operationsinvo1vin positivereactivi y additions r that could result in loss of required SDM or boron concentration
AND
025 Initiate action to restore required DC electrical )owerSUbs~stem(s to OPER BLE status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
IITIOediate1y
Immediately
SAN ONOFRE--UNIT 2 38-28 Amendment No e+8226
Inverters - Shutdown 38B
38 ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 388 Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s required by LCO 3810 Distribution Sys terns - Shutdown II
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQU I RED ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1 Declare affected required feature(s) inoperable
OR
A2l Suspend CORE ALTERATIONS
Immediately
Immediately
A22 Suspend movement of fuel assemblies within containment
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storagepool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-36 Amendment No f15226
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
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4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
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ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
338 CPIS
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicableconditions and required actions of LCO 3415 uReS Leak Detect ion II
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable ---------------~------------01 Place and maintain
containment purgesupply and exhaust valves in closed pos ition
OR
021 Suspend CORE AL TERATIONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in eonta i nment
Immediately
SURVEILLANC~ REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 2 33-36 Amendment No tSr226
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
lCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES I 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES--------------------------- shy1 The provisions of lCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable 1n MODES I 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanupSystem (CREACUS) 1n isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 2 33-39 Amendment No ~226
CRIS 339
ACTIONS (continued) CONDITION REQU IRED ACTI ON COMPLETION TIME
B CRrS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
B1
OR
B21
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode i noperabl e
Place one CREACUS train in emergencymode
Suspend movement of fuel assemblies within containment
Immediately
Immediately
B22
AND
Suspend movement of fuel assemblies in the fuel storagepool
B23 --------NOTE--------shyLimited plant control operations are allowed provided the changes are accounted for in the calculated SDM
Immediately
Immediately
Suspend positivereactivity additions
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor channe1
12 hours
(continued)
SAN ONOFRE--UNIT 2 33-40 Amendment No +15226
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCO 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES I 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicable when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inoperable due to inoperable CRE boundary in Modes 1 2 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant exposures to radiologicalchemical and smoke hazards will not exceed limits
Restore eRE boundary to OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 2 37-24 Amendment No m226
CREACUS 3711
ACTIONS (continued)
CONDITION
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1 2 3 or 4
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
C 1 Be in MODE 3
AND
C2 Be in MODE 5
D1
OR
021
AND
D22
AND
D23
Place OPERABLE CREACUS train in emergency radiation protection mode
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
6 hours
36 hours
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 37-25 Amendment No rt4226
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
E Two CREACUS trains inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E1 Suspend CORE ALTERATIONS
AND
E2 Suspend movement of fuel assemblies within containment
AND
Immediately
Immediately
One or more CREACUS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E3 Suspend movement of fuel assemblies in the fuel storage pool
Immediately
(continued)
SAN ONOFRE--UNIT 2 37-25a Amendment Nolt4226
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCD 3716 The fuel storage pool water level shall be pound 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage poolwater level not within 1imit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is ~ 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 2 37-29 Amendment No irJ226
AC Sources - Shutdown 382
3B ELECTRICAL POWER SYSTEMS
382 AC Sources-Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualified circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3810 Distribution Systems Shutdown and
b One diesel generator (OG) capable of supplying one train of the onsite Class IE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCO 3B10 with one requiredtrain de-energized as a result of Condition A
A Declare affected required feature(s) with no offsite poweravailable inoperfrble
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-17 Amendment No frr226
AC Sources - Shutdown 382
ACTIONS
CONDITION REQU IRED ACTI ON COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-18 Amendment No +r5226
AC Sources - ShlJtdown 382
CONDITION REQUIRED ACTION COMPLETION TIME
B One required DG inoperable
B1
AND
B2
AND
B3
AND
B4
AND
B5
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Initiate action to restore required DG to OPERABLE status
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 38-18a Amendment No 226
DC Sources - Shutdown 3B5
3B ELECTRICAL POWER SYSTEMS
3B5 DC Sources Shutdown
LCO 385 The DC e1ectrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3B10 Distribution Systems - Shutdown
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------shyLCO 303 is not applicable
CONDITION
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
---------------------shyOne or two requiredbattery charger(s) on one train inoperable
REQUIRED ACTION
AI Restore battery terminal voltage to greater than or equal to the minimum estatilished float voltage
AND A2 Verify battery float
current ~ 150 amps
AND
A31
QR
Restore required battery charger(s) to OPERABLE status bull
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s) to OPERABLE status
COMPLETION TIME
2 hours
Once per 12 hours
72 hOlirs
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 2 38-27 Amendment No rtS226
DC Sources - Shutdown 385
CONDITION REQUIRED ACTION
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
D1 Declare affected reguired feature(s) inoperable
ill D21 Sus~end CORE
ALT RATIONS
AND
022 sus~end movement of fue assemblies within containment
AND
023 Sus~end movement of fue assemblies in the fuel storagepool
AND
024 Suspend operationsinvo1vin positivereactivi y additions r that could result in loss of required SDM or boron concentration
AND
025 Initiate action to restore required DC electrical )owerSUbs~stem(s to OPER BLE status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
IITIOediate1y
Immediately
SAN ONOFRE--UNIT 2 38-28 Amendment No e+8226
Inverters - Shutdown 38B
38 ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 388 Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s required by LCO 3810 Distribution Sys terns - Shutdown II
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQU I RED ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1 Declare affected required feature(s) inoperable
OR
A2l Suspend CORE ALTERATIONS
Immediately
Immediately
A22 Suspend movement of fuel assemblies within containment
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storagepool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-36 Amendment No f15226
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
lCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES I 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES--------------------------- shy1 The provisions of lCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable 1n MODES I 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanupSystem (CREACUS) 1n isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 2 33-39 Amendment No ~226
CRIS 339
ACTIONS (continued) CONDITION REQU IRED ACTI ON COMPLETION TIME
B CRrS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
B1
OR
B21
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode i noperabl e
Place one CREACUS train in emergencymode
Suspend movement of fuel assemblies within containment
Immediately
Immediately
B22
AND
Suspend movement of fuel assemblies in the fuel storagepool
B23 --------NOTE--------shyLimited plant control operations are allowed provided the changes are accounted for in the calculated SDM
Immediately
Immediately
Suspend positivereactivity additions
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor channe1
12 hours
(continued)
SAN ONOFRE--UNIT 2 33-40 Amendment No +15226
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCO 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES I 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicable when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inoperable due to inoperable CRE boundary in Modes 1 2 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant exposures to radiologicalchemical and smoke hazards will not exceed limits
Restore eRE boundary to OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 2 37-24 Amendment No m226
CREACUS 3711
ACTIONS (continued)
CONDITION
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1 2 3 or 4
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
C 1 Be in MODE 3
AND
C2 Be in MODE 5
D1
OR
021
AND
D22
AND
D23
Place OPERABLE CREACUS train in emergency radiation protection mode
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
6 hours
36 hours
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 37-25 Amendment No rt4226
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
E Two CREACUS trains inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E1 Suspend CORE ALTERATIONS
AND
E2 Suspend movement of fuel assemblies within containment
AND
Immediately
Immediately
One or more CREACUS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E3 Suspend movement of fuel assemblies in the fuel storage pool
Immediately
(continued)
SAN ONOFRE--UNIT 2 37-25a Amendment Nolt4226
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCD 3716 The fuel storage pool water level shall be pound 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage poolwater level not within 1imit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is ~ 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 2 37-29 Amendment No irJ226
AC Sources - Shutdown 382
3B ELECTRICAL POWER SYSTEMS
382 AC Sources-Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualified circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3810 Distribution Systems Shutdown and
b One diesel generator (OG) capable of supplying one train of the onsite Class IE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCO 3B10 with one requiredtrain de-energized as a result of Condition A
A Declare affected required feature(s) with no offsite poweravailable inoperfrble
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-17 Amendment No frr226
AC Sources - Shutdown 382
ACTIONS
CONDITION REQU IRED ACTI ON COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-18 Amendment No +r5226
AC Sources - ShlJtdown 382
CONDITION REQUIRED ACTION COMPLETION TIME
B One required DG inoperable
B1
AND
B2
AND
B3
AND
B4
AND
B5
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Initiate action to restore required DG to OPERABLE status
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 38-18a Amendment No 226
DC Sources - Shutdown 3B5
3B ELECTRICAL POWER SYSTEMS
3B5 DC Sources Shutdown
LCO 385 The DC e1ectrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3B10 Distribution Systems - Shutdown
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------shyLCO 303 is not applicable
CONDITION
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
---------------------shyOne or two requiredbattery charger(s) on one train inoperable
REQUIRED ACTION
AI Restore battery terminal voltage to greater than or equal to the minimum estatilished float voltage
AND A2 Verify battery float
current ~ 150 amps
AND
A31
QR
Restore required battery charger(s) to OPERABLE status bull
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s) to OPERABLE status
COMPLETION TIME
2 hours
Once per 12 hours
72 hOlirs
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 2 38-27 Amendment No rtS226
DC Sources - Shutdown 385
CONDITION REQUIRED ACTION
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
D1 Declare affected reguired feature(s) inoperable
ill D21 Sus~end CORE
ALT RATIONS
AND
022 sus~end movement of fue assemblies within containment
AND
023 Sus~end movement of fue assemblies in the fuel storagepool
AND
024 Suspend operationsinvo1vin positivereactivi y additions r that could result in loss of required SDM or boron concentration
AND
025 Initiate action to restore required DC electrical )owerSUbs~stem(s to OPER BLE status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
IITIOediate1y
Immediately
SAN ONOFRE--UNIT 2 38-28 Amendment No e+8226
Inverters - Shutdown 38B
38 ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 388 Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s required by LCO 3810 Distribution Sys terns - Shutdown II
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQU I RED ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1 Declare affected required feature(s) inoperable
OR
A2l Suspend CORE ALTERATIONS
Immediately
Immediately
A22 Suspend movement of fuel assemblies within containment
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storagepool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-36 Amendment No f15226
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
CRIS 339
ACTIONS (continued) CONDITION REQU IRED ACTI ON COMPLETION TIME
B CRrS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
B1
OR
B21
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode i noperabl e
Place one CREACUS train in emergencymode
Suspend movement of fuel assemblies within containment
Immediately
Immediately
B22
AND
Suspend movement of fuel assemblies in the fuel storagepool
B23 --------NOTE--------shyLimited plant control operations are allowed provided the changes are accounted for in the calculated SDM
Immediately
Immediately
Suspend positivereactivity additions
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor channe1
12 hours
(continued)
SAN ONOFRE--UNIT 2 33-40 Amendment No +15226
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCO 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES I 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicable when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inoperable due to inoperable CRE boundary in Modes 1 2 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant exposures to radiologicalchemical and smoke hazards will not exceed limits
Restore eRE boundary to OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 2 37-24 Amendment No m226
CREACUS 3711
ACTIONS (continued)
CONDITION
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1 2 3 or 4
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
C 1 Be in MODE 3
AND
C2 Be in MODE 5
D1
OR
021
AND
D22
AND
D23
Place OPERABLE CREACUS train in emergency radiation protection mode
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
6 hours
36 hours
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 37-25 Amendment No rt4226
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
E Two CREACUS trains inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E1 Suspend CORE ALTERATIONS
AND
E2 Suspend movement of fuel assemblies within containment
AND
Immediately
Immediately
One or more CREACUS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E3 Suspend movement of fuel assemblies in the fuel storage pool
Immediately
(continued)
SAN ONOFRE--UNIT 2 37-25a Amendment Nolt4226
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCD 3716 The fuel storage pool water level shall be pound 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage poolwater level not within 1imit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is ~ 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 2 37-29 Amendment No irJ226
AC Sources - Shutdown 382
3B ELECTRICAL POWER SYSTEMS
382 AC Sources-Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualified circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3810 Distribution Systems Shutdown and
b One diesel generator (OG) capable of supplying one train of the onsite Class IE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCO 3B10 with one requiredtrain de-energized as a result of Condition A
A Declare affected required feature(s) with no offsite poweravailable inoperfrble
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-17 Amendment No frr226
AC Sources - Shutdown 382
ACTIONS
CONDITION REQU IRED ACTI ON COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-18 Amendment No +r5226
AC Sources - ShlJtdown 382
CONDITION REQUIRED ACTION COMPLETION TIME
B One required DG inoperable
B1
AND
B2
AND
B3
AND
B4
AND
B5
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Initiate action to restore required DG to OPERABLE status
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 38-18a Amendment No 226
DC Sources - Shutdown 3B5
3B ELECTRICAL POWER SYSTEMS
3B5 DC Sources Shutdown
LCO 385 The DC e1ectrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3B10 Distribution Systems - Shutdown
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------shyLCO 303 is not applicable
CONDITION
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
---------------------shyOne or two requiredbattery charger(s) on one train inoperable
REQUIRED ACTION
AI Restore battery terminal voltage to greater than or equal to the minimum estatilished float voltage
AND A2 Verify battery float
current ~ 150 amps
AND
A31
QR
Restore required battery charger(s) to OPERABLE status bull
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s) to OPERABLE status
COMPLETION TIME
2 hours
Once per 12 hours
72 hOlirs
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 2 38-27 Amendment No rtS226
DC Sources - Shutdown 385
CONDITION REQUIRED ACTION
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
D1 Declare affected reguired feature(s) inoperable
ill D21 Sus~end CORE
ALT RATIONS
AND
022 sus~end movement of fue assemblies within containment
AND
023 Sus~end movement of fue assemblies in the fuel storagepool
AND
024 Suspend operationsinvo1vin positivereactivi y additions r that could result in loss of required SDM or boron concentration
AND
025 Initiate action to restore required DC electrical )owerSUbs~stem(s to OPER BLE status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
IITIOediate1y
Immediately
SAN ONOFRE--UNIT 2 38-28 Amendment No e+8226
Inverters - Shutdown 38B
38 ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 388 Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s required by LCO 3810 Distribution Sys terns - Shutdown II
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQU I RED ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1 Declare affected required feature(s) inoperable
OR
A2l Suspend CORE ALTERATIONS
Immediately
Immediately
A22 Suspend movement of fuel assemblies within containment
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storagepool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-36 Amendment No f15226
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
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Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
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(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCO 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES I 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicable when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inoperable due to inoperable CRE boundary in Modes 1 2 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant exposures to radiologicalchemical and smoke hazards will not exceed limits
Restore eRE boundary to OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 2 37-24 Amendment No m226
CREACUS 3711
ACTIONS (continued)
CONDITION
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1 2 3 or 4
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
C 1 Be in MODE 3
AND
C2 Be in MODE 5
D1
OR
021
AND
D22
AND
D23
Place OPERABLE CREACUS train in emergency radiation protection mode
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
6 hours
36 hours
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 37-25 Amendment No rt4226
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
E Two CREACUS trains inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E1 Suspend CORE ALTERATIONS
AND
E2 Suspend movement of fuel assemblies within containment
AND
Immediately
Immediately
One or more CREACUS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E3 Suspend movement of fuel assemblies in the fuel storage pool
Immediately
(continued)
SAN ONOFRE--UNIT 2 37-25a Amendment Nolt4226
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCD 3716 The fuel storage pool water level shall be pound 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage poolwater level not within 1imit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is ~ 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 2 37-29 Amendment No irJ226
AC Sources - Shutdown 382
3B ELECTRICAL POWER SYSTEMS
382 AC Sources-Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualified circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3810 Distribution Systems Shutdown and
b One diesel generator (OG) capable of supplying one train of the onsite Class IE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCO 3B10 with one requiredtrain de-energized as a result of Condition A
A Declare affected required feature(s) with no offsite poweravailable inoperfrble
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-17 Amendment No frr226
AC Sources - Shutdown 382
ACTIONS
CONDITION REQU IRED ACTI ON COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-18 Amendment No +r5226
AC Sources - ShlJtdown 382
CONDITION REQUIRED ACTION COMPLETION TIME
B One required DG inoperable
B1
AND
B2
AND
B3
AND
B4
AND
B5
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Initiate action to restore required DG to OPERABLE status
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 38-18a Amendment No 226
DC Sources - Shutdown 3B5
3B ELECTRICAL POWER SYSTEMS
3B5 DC Sources Shutdown
LCO 385 The DC e1ectrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3B10 Distribution Systems - Shutdown
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------shyLCO 303 is not applicable
CONDITION
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
---------------------shyOne or two requiredbattery charger(s) on one train inoperable
REQUIRED ACTION
AI Restore battery terminal voltage to greater than or equal to the minimum estatilished float voltage
AND A2 Verify battery float
current ~ 150 amps
AND
A31
QR
Restore required battery charger(s) to OPERABLE status bull
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s) to OPERABLE status
COMPLETION TIME
2 hours
Once per 12 hours
72 hOlirs
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 2 38-27 Amendment No rtS226
DC Sources - Shutdown 385
CONDITION REQUIRED ACTION
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
D1 Declare affected reguired feature(s) inoperable
ill D21 Sus~end CORE
ALT RATIONS
AND
022 sus~end movement of fue assemblies within containment
AND
023 Sus~end movement of fue assemblies in the fuel storagepool
AND
024 Suspend operationsinvo1vin positivereactivi y additions r that could result in loss of required SDM or boron concentration
AND
025 Initiate action to restore required DC electrical )owerSUbs~stem(s to OPER BLE status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
IITIOediate1y
Immediately
SAN ONOFRE--UNIT 2 38-28 Amendment No e+8226
Inverters - Shutdown 38B
38 ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 388 Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s required by LCO 3810 Distribution Sys terns - Shutdown II
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQU I RED ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1 Declare affected required feature(s) inoperable
OR
A2l Suspend CORE ALTERATIONS
Immediately
Immediately
A22 Suspend movement of fuel assemblies within containment
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storagepool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-36 Amendment No f15226
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
CREACUS 3711
ACTIONS (continued)
CONDITION
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1 2 3 or 4
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
C 1 Be in MODE 3
AND
C2 Be in MODE 5
D1
OR
021
AND
D22
AND
D23
Place OPERABLE CREACUS train in emergency radiation protection mode
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
6 hours
36 hours
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 37-25 Amendment No rt4226
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
E Two CREACUS trains inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E1 Suspend CORE ALTERATIONS
AND
E2 Suspend movement of fuel assemblies within containment
AND
Immediately
Immediately
One or more CREACUS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E3 Suspend movement of fuel assemblies in the fuel storage pool
Immediately
(continued)
SAN ONOFRE--UNIT 2 37-25a Amendment Nolt4226
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCD 3716 The fuel storage pool water level shall be pound 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage poolwater level not within 1imit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is ~ 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 2 37-29 Amendment No irJ226
AC Sources - Shutdown 382
3B ELECTRICAL POWER SYSTEMS
382 AC Sources-Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualified circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3810 Distribution Systems Shutdown and
b One diesel generator (OG) capable of supplying one train of the onsite Class IE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCO 3B10 with one requiredtrain de-energized as a result of Condition A
A Declare affected required feature(s) with no offsite poweravailable inoperfrble
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-17 Amendment No frr226
AC Sources - Shutdown 382
ACTIONS
CONDITION REQU IRED ACTI ON COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-18 Amendment No +r5226
AC Sources - ShlJtdown 382
CONDITION REQUIRED ACTION COMPLETION TIME
B One required DG inoperable
B1
AND
B2
AND
B3
AND
B4
AND
B5
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Initiate action to restore required DG to OPERABLE status
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 38-18a Amendment No 226
DC Sources - Shutdown 3B5
3B ELECTRICAL POWER SYSTEMS
3B5 DC Sources Shutdown
LCO 385 The DC e1ectrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3B10 Distribution Systems - Shutdown
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------shyLCO 303 is not applicable
CONDITION
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
---------------------shyOne or two requiredbattery charger(s) on one train inoperable
REQUIRED ACTION
AI Restore battery terminal voltage to greater than or equal to the minimum estatilished float voltage
AND A2 Verify battery float
current ~ 150 amps
AND
A31
QR
Restore required battery charger(s) to OPERABLE status bull
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s) to OPERABLE status
COMPLETION TIME
2 hours
Once per 12 hours
72 hOlirs
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 2 38-27 Amendment No rtS226
DC Sources - Shutdown 385
CONDITION REQUIRED ACTION
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
D1 Declare affected reguired feature(s) inoperable
ill D21 Sus~end CORE
ALT RATIONS
AND
022 sus~end movement of fue assemblies within containment
AND
023 Sus~end movement of fue assemblies in the fuel storagepool
AND
024 Suspend operationsinvo1vin positivereactivi y additions r that could result in loss of required SDM or boron concentration
AND
025 Initiate action to restore required DC electrical )owerSUbs~stem(s to OPER BLE status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
IITIOediate1y
Immediately
SAN ONOFRE--UNIT 2 38-28 Amendment No e+8226
Inverters - Shutdown 38B
38 ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 388 Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s required by LCO 3810 Distribution Sys terns - Shutdown II
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQU I RED ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1 Declare affected required feature(s) inoperable
OR
A2l Suspend CORE ALTERATIONS
Immediately
Immediately
A22 Suspend movement of fuel assemblies within containment
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storagepool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-36 Amendment No f15226
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
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bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
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bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
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D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
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Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
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assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
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TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
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Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
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containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
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Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
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Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
E Two CREACUS trains inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E1 Suspend CORE ALTERATIONS
AND
E2 Suspend movement of fuel assemblies within containment
AND
Immediately
Immediately
One or more CREACUS trains inoperable due to an inoperable CRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
E3 Suspend movement of fuel assemblies in the fuel storage pool
Immediately
(continued)
SAN ONOFRE--UNIT 2 37-25a Amendment Nolt4226
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCD 3716 The fuel storage pool water level shall be pound 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage poolwater level not within 1imit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is ~ 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 2 37-29 Amendment No irJ226
AC Sources - Shutdown 382
3B ELECTRICAL POWER SYSTEMS
382 AC Sources-Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualified circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3810 Distribution Systems Shutdown and
b One diesel generator (OG) capable of supplying one train of the onsite Class IE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCO 3B10 with one requiredtrain de-energized as a result of Condition A
A Declare affected required feature(s) with no offsite poweravailable inoperfrble
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-17 Amendment No frr226
AC Sources - Shutdown 382
ACTIONS
CONDITION REQU IRED ACTI ON COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-18 Amendment No +r5226
AC Sources - ShlJtdown 382
CONDITION REQUIRED ACTION COMPLETION TIME
B One required DG inoperable
B1
AND
B2
AND
B3
AND
B4
AND
B5
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Initiate action to restore required DG to OPERABLE status
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 38-18a Amendment No 226
DC Sources - Shutdown 3B5
3B ELECTRICAL POWER SYSTEMS
3B5 DC Sources Shutdown
LCO 385 The DC e1ectrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3B10 Distribution Systems - Shutdown
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------shyLCO 303 is not applicable
CONDITION
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
---------------------shyOne or two requiredbattery charger(s) on one train inoperable
REQUIRED ACTION
AI Restore battery terminal voltage to greater than or equal to the minimum estatilished float voltage
AND A2 Verify battery float
current ~ 150 amps
AND
A31
QR
Restore required battery charger(s) to OPERABLE status bull
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s) to OPERABLE status
COMPLETION TIME
2 hours
Once per 12 hours
72 hOlirs
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 2 38-27 Amendment No rtS226
DC Sources - Shutdown 385
CONDITION REQUIRED ACTION
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
D1 Declare affected reguired feature(s) inoperable
ill D21 Sus~end CORE
ALT RATIONS
AND
022 sus~end movement of fue assemblies within containment
AND
023 Sus~end movement of fue assemblies in the fuel storagepool
AND
024 Suspend operationsinvo1vin positivereactivi y additions r that could result in loss of required SDM or boron concentration
AND
025 Initiate action to restore required DC electrical )owerSUbs~stem(s to OPER BLE status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
IITIOediate1y
Immediately
SAN ONOFRE--UNIT 2 38-28 Amendment No e+8226
Inverters - Shutdown 38B
38 ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 388 Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s required by LCO 3810 Distribution Sys terns - Shutdown II
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQU I RED ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1 Declare affected required feature(s) inoperable
OR
A2l Suspend CORE ALTERATIONS
Immediately
Immediately
A22 Suspend movement of fuel assemblies within containment
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storagepool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-36 Amendment No f15226
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
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4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
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bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
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bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
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D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
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Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
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assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
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TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
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Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
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containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
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Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
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Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCD 3716 The fuel storage pool water level shall be pound 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage poolwater level not within 1imit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is ~ 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 2 37-29 Amendment No irJ226
AC Sources - Shutdown 382
3B ELECTRICAL POWER SYSTEMS
382 AC Sources-Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualified circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3810 Distribution Systems Shutdown and
b One diesel generator (OG) capable of supplying one train of the onsite Class IE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCO 3B10 with one requiredtrain de-energized as a result of Condition A
A Declare affected required feature(s) with no offsite poweravailable inoperfrble
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-17 Amendment No frr226
AC Sources - Shutdown 382
ACTIONS
CONDITION REQU IRED ACTI ON COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-18 Amendment No +r5226
AC Sources - ShlJtdown 382
CONDITION REQUIRED ACTION COMPLETION TIME
B One required DG inoperable
B1
AND
B2
AND
B3
AND
B4
AND
B5
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Initiate action to restore required DG to OPERABLE status
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 38-18a Amendment No 226
DC Sources - Shutdown 3B5
3B ELECTRICAL POWER SYSTEMS
3B5 DC Sources Shutdown
LCO 385 The DC e1ectrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3B10 Distribution Systems - Shutdown
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------shyLCO 303 is not applicable
CONDITION
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
---------------------shyOne or two requiredbattery charger(s) on one train inoperable
REQUIRED ACTION
AI Restore battery terminal voltage to greater than or equal to the minimum estatilished float voltage
AND A2 Verify battery float
current ~ 150 amps
AND
A31
QR
Restore required battery charger(s) to OPERABLE status bull
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s) to OPERABLE status
COMPLETION TIME
2 hours
Once per 12 hours
72 hOlirs
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 2 38-27 Amendment No rtS226
DC Sources - Shutdown 385
CONDITION REQUIRED ACTION
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
D1 Declare affected reguired feature(s) inoperable
ill D21 Sus~end CORE
ALT RATIONS
AND
022 sus~end movement of fue assemblies within containment
AND
023 Sus~end movement of fue assemblies in the fuel storagepool
AND
024 Suspend operationsinvo1vin positivereactivi y additions r that could result in loss of required SDM or boron concentration
AND
025 Initiate action to restore required DC electrical )owerSUbs~stem(s to OPER BLE status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
IITIOediate1y
Immediately
SAN ONOFRE--UNIT 2 38-28 Amendment No e+8226
Inverters - Shutdown 38B
38 ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 388 Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s required by LCO 3810 Distribution Sys terns - Shutdown II
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQU I RED ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1 Declare affected required feature(s) inoperable
OR
A2l Suspend CORE ALTERATIONS
Immediately
Immediately
A22 Suspend movement of fuel assemblies within containment
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storagepool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-36 Amendment No f15226
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
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(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
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4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
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bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
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bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
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D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
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Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
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assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
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TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
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Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
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containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
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Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
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Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
AC Sources - Shutdown 382
3B ELECTRICAL POWER SYSTEMS
382 AC Sources-Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualified circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3810 Distribution Systems Shutdown and
b One diesel generator (OG) capable of supplying one train of the onsite Class IE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCO 3B10 with one requiredtrain de-energized as a result of Condition A
A Declare affected required feature(s) with no offsite poweravailable inoperfrble
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-17 Amendment No frr226
AC Sources - Shutdown 382
ACTIONS
CONDITION REQU IRED ACTI ON COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-18 Amendment No +r5226
AC Sources - ShlJtdown 382
CONDITION REQUIRED ACTION COMPLETION TIME
B One required DG inoperable
B1
AND
B2
AND
B3
AND
B4
AND
B5
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Initiate action to restore required DG to OPERABLE status
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 38-18a Amendment No 226
DC Sources - Shutdown 3B5
3B ELECTRICAL POWER SYSTEMS
3B5 DC Sources Shutdown
LCO 385 The DC e1ectrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3B10 Distribution Systems - Shutdown
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------shyLCO 303 is not applicable
CONDITION
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
---------------------shyOne or two requiredbattery charger(s) on one train inoperable
REQUIRED ACTION
AI Restore battery terminal voltage to greater than or equal to the minimum estatilished float voltage
AND A2 Verify battery float
current ~ 150 amps
AND
A31
QR
Restore required battery charger(s) to OPERABLE status bull
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s) to OPERABLE status
COMPLETION TIME
2 hours
Once per 12 hours
72 hOlirs
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 2 38-27 Amendment No rtS226
DC Sources - Shutdown 385
CONDITION REQUIRED ACTION
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
D1 Declare affected reguired feature(s) inoperable
ill D21 Sus~end CORE
ALT RATIONS
AND
022 sus~end movement of fue assemblies within containment
AND
023 Sus~end movement of fue assemblies in the fuel storagepool
AND
024 Suspend operationsinvo1vin positivereactivi y additions r that could result in loss of required SDM or boron concentration
AND
025 Initiate action to restore required DC electrical )owerSUbs~stem(s to OPER BLE status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
IITIOediate1y
Immediately
SAN ONOFRE--UNIT 2 38-28 Amendment No e+8226
Inverters - Shutdown 38B
38 ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 388 Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s required by LCO 3810 Distribution Sys terns - Shutdown II
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQU I RED ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1 Declare affected required feature(s) inoperable
OR
A2l Suspend CORE ALTERATIONS
Immediately
Immediately
A22 Suspend movement of fuel assemblies within containment
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storagepool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-36 Amendment No f15226
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
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(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
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4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
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bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
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bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
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D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
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Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
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assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
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TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
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Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
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Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
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Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
AC Sources - Shutdown 382
ACTIONS
CONDITION REQU IRED ACTI ON COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-18 Amendment No +r5226
AC Sources - ShlJtdown 382
CONDITION REQUIRED ACTION COMPLETION TIME
B One required DG inoperable
B1
AND
B2
AND
B3
AND
B4
AND
B5
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Initiate action to restore required DG to OPERABLE status
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 38-18a Amendment No 226
DC Sources - Shutdown 3B5
3B ELECTRICAL POWER SYSTEMS
3B5 DC Sources Shutdown
LCO 385 The DC e1ectrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3B10 Distribution Systems - Shutdown
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------shyLCO 303 is not applicable
CONDITION
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
---------------------shyOne or two requiredbattery charger(s) on one train inoperable
REQUIRED ACTION
AI Restore battery terminal voltage to greater than or equal to the minimum estatilished float voltage
AND A2 Verify battery float
current ~ 150 amps
AND
A31
QR
Restore required battery charger(s) to OPERABLE status bull
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s) to OPERABLE status
COMPLETION TIME
2 hours
Once per 12 hours
72 hOlirs
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 2 38-27 Amendment No rtS226
DC Sources - Shutdown 385
CONDITION REQUIRED ACTION
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
D1 Declare affected reguired feature(s) inoperable
ill D21 Sus~end CORE
ALT RATIONS
AND
022 sus~end movement of fue assemblies within containment
AND
023 Sus~end movement of fue assemblies in the fuel storagepool
AND
024 Suspend operationsinvo1vin positivereactivi y additions r that could result in loss of required SDM or boron concentration
AND
025 Initiate action to restore required DC electrical )owerSUbs~stem(s to OPER BLE status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
IITIOediate1y
Immediately
SAN ONOFRE--UNIT 2 38-28 Amendment No e+8226
Inverters - Shutdown 38B
38 ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 388 Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s required by LCO 3810 Distribution Sys terns - Shutdown II
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQU I RED ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1 Declare affected required feature(s) inoperable
OR
A2l Suspend CORE ALTERATIONS
Immediately
Immediately
A22 Suspend movement of fuel assemblies within containment
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storagepool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-36 Amendment No f15226
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
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4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
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bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
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bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
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D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
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Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
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assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
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TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
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Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
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containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
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Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
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Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
AC Sources - ShlJtdown 382
CONDITION REQUIRED ACTION COMPLETION TIME
B One required DG inoperable
B1
AND
B2
AND
B3
AND
B4
AND
B5
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Suspend movement of fuel assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Initiate action to restore required DG to OPERABLE status
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 2 38-18a Amendment No 226
DC Sources - Shutdown 3B5
3B ELECTRICAL POWER SYSTEMS
3B5 DC Sources Shutdown
LCO 385 The DC e1ectrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3B10 Distribution Systems - Shutdown
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------shyLCO 303 is not applicable
CONDITION
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
---------------------shyOne or two requiredbattery charger(s) on one train inoperable
REQUIRED ACTION
AI Restore battery terminal voltage to greater than or equal to the minimum estatilished float voltage
AND A2 Verify battery float
current ~ 150 amps
AND
A31
QR
Restore required battery charger(s) to OPERABLE status bull
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s) to OPERABLE status
COMPLETION TIME
2 hours
Once per 12 hours
72 hOlirs
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 2 38-27 Amendment No rtS226
DC Sources - Shutdown 385
CONDITION REQUIRED ACTION
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
D1 Declare affected reguired feature(s) inoperable
ill D21 Sus~end CORE
ALT RATIONS
AND
022 sus~end movement of fue assemblies within containment
AND
023 Sus~end movement of fue assemblies in the fuel storagepool
AND
024 Suspend operationsinvo1vin positivereactivi y additions r that could result in loss of required SDM or boron concentration
AND
025 Initiate action to restore required DC electrical )owerSUbs~stem(s to OPER BLE status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
IITIOediate1y
Immediately
SAN ONOFRE--UNIT 2 38-28 Amendment No e+8226
Inverters - Shutdown 38B
38 ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 388 Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s required by LCO 3810 Distribution Sys terns - Shutdown II
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQU I RED ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1 Declare affected required feature(s) inoperable
OR
A2l Suspend CORE ALTERATIONS
Immediately
Immediately
A22 Suspend movement of fuel assemblies within containment
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storagepool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-36 Amendment No f15226
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
DC Sources - Shutdown 3B5
3B ELECTRICAL POWER SYSTEMS
3B5 DC Sources Shutdown
LCO 385 The DC e1ectrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3B10 Distribution Systems - Shutdown
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------shyLCO 303 is not applicable
CONDITION
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
---------------------shyOne or two requiredbattery charger(s) on one train inoperable
REQUIRED ACTION
AI Restore battery terminal voltage to greater than or equal to the minimum estatilished float voltage
AND A2 Verify battery float
current ~ 150 amps
AND
A31
QR
Restore required battery charger(s) to OPERABLE status bull
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s) to OPERABLE status
COMPLETION TIME
2 hours
Once per 12 hours
72 hOlirs
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 2 38-27 Amendment No rtS226
DC Sources - Shutdown 385
CONDITION REQUIRED ACTION
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
D1 Declare affected reguired feature(s) inoperable
ill D21 Sus~end CORE
ALT RATIONS
AND
022 sus~end movement of fue assemblies within containment
AND
023 Sus~end movement of fue assemblies in the fuel storagepool
AND
024 Suspend operationsinvo1vin positivereactivi y additions r that could result in loss of required SDM or boron concentration
AND
025 Initiate action to restore required DC electrical )owerSUbs~stem(s to OPER BLE status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
IITIOediate1y
Immediately
SAN ONOFRE--UNIT 2 38-28 Amendment No e+8226
Inverters - Shutdown 38B
38 ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 388 Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s required by LCO 3810 Distribution Sys terns - Shutdown II
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQU I RED ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1 Declare affected required feature(s) inoperable
OR
A2l Suspend CORE ALTERATIONS
Immediately
Immediately
A22 Suspend movement of fuel assemblies within containment
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storagepool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-36 Amendment No f15226
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
DC Sources - Shutdown 385
CONDITION REQUIRED ACTION
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
D1 Declare affected reguired feature(s) inoperable
ill D21 Sus~end CORE
ALT RATIONS
AND
022 sus~end movement of fue assemblies within containment
AND
023 Sus~end movement of fue assemblies in the fuel storagepool
AND
024 Suspend operationsinvo1vin positivereactivi y additions r that could result in loss of required SDM or boron concentration
AND
025 Initiate action to restore required DC electrical )owerSUbs~stem(s to OPER BLE status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
IITIOediate1y
Immediately
SAN ONOFRE--UNIT 2 38-28 Amendment No e+8226
Inverters - Shutdown 38B
38 ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 388 Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s required by LCO 3810 Distribution Sys terns - Shutdown II
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQU I RED ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1 Declare affected required feature(s) inoperable
OR
A2l Suspend CORE ALTERATIONS
Immediately
Immediately
A22 Suspend movement of fuel assemblies within containment
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storagepool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-36 Amendment No f15226
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
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(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
Inverters - Shutdown 38B
38 ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 388 Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s required by LCO 3810 Distribution Sys terns - Shutdown II
APPLICABILITY MODES 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQU I RED ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1 Declare affected required feature(s) inoperable
OR
A2l Suspend CORE ALTERATIONS
Immediately
Immediately
A22 Suspend movement of fuel assemblies within containment
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storagepool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-36 Amendment No f15226
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
Inverters - Shutdown 3B8
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEIllANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 2 38-37 Amendment No f21226
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
AI Declare associated sup~orted requiredfea ure(s) inoperable
OR
A21 Sus~end CORE ALI RATIONS
AND
A22 Sus~end movement of fue assemblies within containment
AND
A23 Sus~end movement of fue assemblies in the fuel storage pool
AND
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SOM or boron concentration
AND
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 2 38-40 Amendment No rlS226
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
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4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
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PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
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NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
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DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
Distribution Systems - Shutdown 3810
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
AND
Immediately
A26 Declare associated required shutdown cooling system(s) inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to reguired AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 2 38-41 Amendment No rts226
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
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(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
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4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
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The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
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bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
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bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
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D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
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Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
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assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
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TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
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Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
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containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
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Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
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Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
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ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCD 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met 1) The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A designated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge is in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door s OPERABLE and
b1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or equivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 2 39-4 Amendment No +93226
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more containment penetrations not in required status
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 2 39-5 Amendment No ~226
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained ~ 23 ft above the top of reactor vessel flange
---------------~---------------------NOTE-------------------------------------Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement of fuel reactor pressure vessel During movement of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Refueling water level not within limit
A1
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 2 39-10 Amendment No -84226
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
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4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
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ADAMS Accession No ML12215A399 OFFICE
NAME
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PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
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NRRlDRAlAADBBC
TTate (lDozier for)
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DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
UNITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
DOCKET NO 50-362
SAN ONOFRE NUCLEAR GENERATING STATION UNIT 3
AMENDMENT TO FACILITY OPERATING LICENSE
Amendment No 219 License No NPF-15
1 The Nuclear Regulatory Commission (the Commission) has found that
A The application for amendment by Southern California Edison Company et al (SCE or the licensee) dated September 2 2011 complies with the standards and requirements of the Atomic Energy Act of 1954 as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I
B The facility will operate in conformity with the application the provisions of the Act and the rules and regulations of the Commission
C There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public and (ii) that such activities will be conducted In compliance with the Commissions regulations
D The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public and
E The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied
Enclosure 2
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2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
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(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
- 2shy
2 Accordingly the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2C(2) of Facility Operating License No NPF-15 is hereby amended to read as follows
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
3 This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance
FOR THE NUCLEAR REGULATORY COMMISSION
Attachment Changes to the Facility
Operating License No NPF-15 and Technical Specifications
Date of Issuance October 16
Michael T Markley Chief Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
2012
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
ATTACHMENT TO LICENSE AMENDMENT NO 219
FACILITY OPERATING LICENSE NO NPF-15
DOCKET NO 50-362
Replace the following pages of the Facility Operating license No NPF-15 and Appendix A Technical Specifications with the attached revised pages The revised pages are identified by amendment number and contain marginal lines indicating the areas of change
Facility Operating license
REMOVE INSERT
-3- -3shy
Technical Specifications
REMOVE INSERT
33-35 33-35 33-36 33-36 33-39 33-39 33-40 33-40 37-24 37-24 37-25 37-25
37-25a 37-29 37-29 38-17 38-17 38-18 38-18
38-18a 38-27 38-27 38-28 38-28 38-36 38-36 38-37 38-37 38-40 38-40 38-41 38-41 39-4 39-4 39-5 39-5 39-10 39-10
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
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TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
-3shy
(3) SCE pursuant to the Act and 10 CFR Part 70 to receive possess and use at any time special nuclear material as reactor fuel in accordance with the limitations for storage and amounts required for reactor operation as described in the Final Safety Analysis Report as supplemented and amended
(4) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use at any time any byproduct source and special nuclear materials as sealed neutron sources for reactor startup sealed sources for reactor instrumentation and radiation monitoring equipment calibration and as fission detectors in amounts as required
(5) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to receive possess and use in amounts as required any byproduct source or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or associated with radioactive apparatus or components and
(6) SCE pursuant to the Act and 10 CFR Parts 30 40 and 70 to possess but not separate such byproduct and special nuclear materials as may be produced by the operation of San Onofre Nuclear Generating Station Units 1 and 3 and by the decommissioning of San Onofre Nuclear Generating Station Unit 1
C This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules regulations and orders of the Commission now or hereafter in effect and is subject to the additional conditions specified or incorporated below
(1) Maximum Power Level
Southern California Edison Company (SCE) is authorized to operate the facility at reactor core power levels not in excess of full power (3438 megawatts thermal)
(2) Technical Specifications
The Technical Specifications contained in Appendix A and the Environmental Protection Plan contained in Appendix B as revised through Amendment No 219 are hereby incorporated in the license Southern California Edison Company shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan
Amendment No 219
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
CPIS 338
33 INSTRUMENTATION
338 Containment Purge Isolation Signal (CPIS)
LCO 338 One CPIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
----------------------------NOTE--------------------------- shyOnly required when the penetration is not isolated byappropriate closed and de-activated automatic valve(s) closed manual valve(s) or blind flanges)
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A CPIS Actuation Logic or one or more required channels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
Al Enter applicable Conditions and Required Actions for affected valves of LCO 363IIContainment Isolation Valves made inoperable byCPIS instrumentation
Immediately
B Required Action and associated CompletionTime not met in MODES I 2 3 or 4
B1
AND
Be in MODE 3 6 hours
B2 Be in MODE 5 36 hours
(continued)
SAN ONOFRE--UNIT 3 33-35 Amendment No t2219
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
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4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
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ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
CPIS 338
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C One or more requiredchannels of containment airborne radiation monitors inoperable in MODES 1 2 3 and 4
C1 Enter applicable conditions and required actions of LCO 3415 RCS Leak Detection 1I
Immediately
D CPIS Manual TripActuation Logic or one or more requiredchannels of containment airborne radiation monitors inoperable during CORE ALTERATIONS or movement of fuel assemblies within containment
-------------NOTE-----------shyThe provisions of LCO 303 are not applicable --------------~--------------01 Place and maintain
containment purgesupply and exhaust valves in closed position
OR
021 Suspend CORE ALTERATI ONS
Immediately
Immediately
AND
022 Suspend movement of fuel assemblies in containment
Immediately
SURVEILLANCE REQUIREMENTS
SURVEI LLANCE FREQUENCY
SR 3381 Perform a CHANNEL CHECK on requiredcontainment airborne radiation monitor channel
12 hours
(continued)
SAN ONOFRE--UNIT 3 33-36 Amendment No trt219
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
CRIS 339
33 INSTRUMENTATION
339 Control Room Isolation Signal (CRIS)
LCO 339 One CRIS channel shall be OPERABLE
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
---------------------------NOTES---------------------------shy1 The provisions of LCO 303 are not applicable2 The provisions of LCO 304 are not applicable
CONDITION REQU I RED ACTI ON COMPLETION TIME
A CRIS Manual TripActuation Logic or one required channel of control room airborne radiation monitors inoperable in MODES 1 2 3 or 4
Al --------NOTE--------shyPlace Control Room Emergency Air CleanopSystem (CREACUS) in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
1 hour
(continued)
SAN ONOFRE--UNIT 3 33-39 Amendment No ~219
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
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ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
---------------------
---------------------
339 CRIS
ACTIONS (continued)
CONDITION
B eRIS Manual TripActuation Logic or required control room airborne radiation monitors inoperable in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies n the fuel storage pool
SURVEILLANCE REQUIREMENTS
B1
OR
B21
AND
B22
AND
B23
REQUIRED ACTION
--------NOTE--------shyPlace CREACUS in isolation mode if automatic transfer to isolation mode inoperable
Place one CREACUS train in emergencymode
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
--------NOTE--------shyLimited plant control o~erations are a lowed provided the changes are accounted for in the calculated SDM
Suspend positivereactivity additions
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
SURVEILLANCE FREQUENCY
SR 3391 Perform a CHANNEL CHECK on the required control room airborne radiation monitor
12 hours
channel
(continued)
SAN ONOFRE--UNIT 3 33-40 Amendment No +amp6219
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
CREACUS 3711
37 PLANT SYSTEMS
3711 Control Room Emergency Air Cleanup System (CREACUS)
LCD 3711 Two CREACUS trains shall be OPERABLE
-------------------------NOTE------------------------------ shyThe control room envelope (CRE) boundary may be openedintermittently under administrative control
APPLICABILITY MODES 1 2 3 4 5 and 6During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------NOTES----------------------------- shy1 The provisions of LCO 304 are not applicabl~ when
entering MODES 5 6 or defueled configuration
2 Each Unit shall enter applicable ACTIONS separately
CONDITION REQUIRED ACTION COMPLETION TIME
A One CREACUS train inoperable for reasons other than Condition B
AI Restore CREACUS train to OPERABLE status
14 days
B One or more CREACUS trains inogerable due to inopera le CRE boundary in Modes 1 2~ 3 or 4
B1
AND
B2
AND
B3
Initiate action to implement mitigatingactions
Verify mitigating actions ensure CRE occupant ex~osures to radiolo~ica chemica and smoke hazards will not exceed limits
Restore CRE boundaryto OPERABLE status
Immediately
24 hours
90 days
(continued)
SAN ONOFRE--UNIT 3 37-24 Amendment No ~219
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
CREACUS 3711
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME
C Required Action and associated CompletionTime of Condition A or B not met in MODE 1
C1 Be in MODE 3
AND
6 hours
2 3 or 4 C2 Be in MODE 5 36 hours
D Required Action and associated CompletionTime of Condition A not met in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
01 Place OPERABLE CREACUS train in emergency radiation protection mode
illi
021 Suspend CORE ALTERATIONS
AND
022 Suspend movement of fuel assemblies within containment
AND
023 Suspend movement of fuel assemblies in the fuel storagepool
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25 Amendment No r96219
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
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Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
CREACUS 3711
ACTIONS (continued)
CONDITION
E Two CREACUS trains inoperable in MODE 5 or 6~ or during movement of fuel assemblies within containment or duringthe movement of fuel assemblies in the fuel storage pool
One or more CREACUS trains inoperable due to an inoperable eRE boundary in MODE 5 or 6 or during movement of fuel assemblies within containment or during the movement of fuel assemblies in the fuel storage pool
REQUIRED ACTION
E1 Suspend CORE ALTERATIONS
AND
[2 Suspend movement of fuel assemblies within containment
AND
[3 Suspend movement of fuel assemblies in the fuel storagepool
COMPLETION TIME
Ill1I1ediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 37-25a Amendment No reb219
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
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(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
Fuel Storage Pool Water Level 3716
37 PLANT SYSTEMS
3716 Fuel Storage Pool Water Level
LCO 3716 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks
APPLICABILITY During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A Fuel storage pool water level not within limit
Al --------NOTE--------shyLCO 303 is not applicable
Suspend movement of fuel assemblies in fuel storage pool
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 37161 Verify the fuel storage pool water level is 2 23 ft above the top of irradiated fuel assemblies seated in the storage racks
7 days
SAN ONOFRE--UNIT 3 37-29 Amendment No t+6219
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
AC Sources - Shutdown 382
38 ELECTRICAL POWER SYSTEMS
382 AC Sources - Shutdown
LCO 382 The following AC electrical power sources shall be OPERABLE
a One qualifted circuit between the offsite transmission network and the onsite Class IE AC electrical powerdistribution subsystem(s) required by LCO 3B10 Distribution Systems Shutdown U
and
b One diesel generator (06) capable of supplying one train of the onsite Class lE AC electrical power distribution subsystem(s) required by LCO 3810
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One required offsite circuit inoperable
------------NOTE------------shyEnter applicable Conditions and Required Actions of LCD 3810 with one requiredtrain de-energized as a result of Condition A
A1 Declare affected required feature(s)with no offsite poweravailable inoperable
OR
A21 Suspend CORE ALTERATIONS
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-17 Amendment No f6219
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
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4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
AC Sources - Shutdown 382
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A22 Suspend movement of fuel assemblies within containment
Immediately
A23 Suspend movement of fuel assemblies in the fuel storage poo 1
Immediately
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
A25 Initiate action to restore requiredoffsite power circuit to OPERABLE status
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-18 Amendment No tt6219
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
382 AC Sources - Shutdown
CONDITION REQUIRED ACTION
B One required DG inoperable
B1 Suspend CORE ALTERATIONS
AND
B2 Sus~end movement of fue assemblies within containment
AND
83 Sus~end movement of fue assemblies in the fuel storagepool
AND
B4 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
AND
B5 Initiate action to restore re~uired DG to OPERABL status
COMPLETION TIME
Immediately
Immediately
Immediately
Immediately
Immediately
SAN ONOFRE--UNIT 3 38-18a Amendment No +ampamp219
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
DC Sources - Shutdown 385
38 ELECTRICAL POWER SYSTEMS
385 DC Sources Shutdown
LCO 385 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCD 3810 UDistribution Systems - Shutdown
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS -------------------------------------NOTE------------------------------------ shyLCO 303 is not applicable
CONDITION REQUIRED ACTION COMPLETION TIME
A ---------NOTE--------shy
Only applicable to 1800 amp-hour rated batteries
------------__------shyOne or two requiredbattery charger(s~ on one train inopera leo
AI Restore battery terminal voltage to greater than or equal to the minimum estaolished float voltage
AND
A2 Verify battery float current ~ 150 amps
AND
A3I Restore required battery charger(s) to OPERABLE status
OR
A321 Provide ability to power the spare battery charger from a diesel-backed source
AND
A322 Restore required battery charger(s to OPERABLE status
2 hours
Once per 12 hours
72 hours
72 hours
7 days
(continued)
SAN ONOFRE--UNIT 3 38-27 Amendment No rtl219
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
DC Sources - Shutdown 3B5
CONDITION REQUIRED ACTION COMPLETION TIME
D One or more requiredDC electrical powersubsystem(s)inoperable for reasons other than Condition A or B
01 Declare affected reguired feature(s) inoperable
OR
021 Sus~end CORE ALT RATIONS
Immediately
Immediately
AND
022 Sus~end movement of fue assembli es within containment
Immediately
AND
023 sus~end movement of fue assemblies in the fuel storagepool
Immediately
AND
024 Suspend operations invo1vin~ positivereactivi y additions that could result in loss of required SDM or boron concentration
Immediately
AND
025 Initiate action to restore required DC electrical )owersUb~stem(s to OPE BlE status
Immediately
SAN ONOFRE--UNIT 3 Amendment No r+t219
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
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(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
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4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
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The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
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bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
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bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
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D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
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Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
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assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
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TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
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Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
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containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
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Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
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Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
Inverters - Shutdown 388
3B ELECTRICAL POWER SYSTEMS
388 Inverters - Shutdown
LCO 38B Required inverters shall be OPERABLE to support the onsite Class IE AC vital bus electrical power distribution subsystem(s) required by LCO 3810 IIDistribution Systems shy Shutdown II
APPLICABILITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS CONDITION REQU I REO ACTI ON COMPLETION TIME
A One or more requiredinverters inoperable
A1
QR
A21
AND
A22
AND
A23
AND
A24
AND
Declare affected required feature(s) inoperable
Suspend CORE ALTERATIONS
sus~end movement of fue assemblies within containment
Sus~end movement of fue assemblies in the fuel storagepool
Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
Immediately
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-36 Amendment No +ampamp219
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
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4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
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bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
Inverters - Shutdown 388
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate action to restore required inverters to OPERABLE status
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3881 Verify correct inverter voltage and 7 daysalignment to required AC vital buses
SAN ONOFRE--UNIT 3 38-37 Amendment No +16219
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
Distribution Systems - Shutdown 3810
38 ELECTRICAL POWER SYSTEMS
3810 Distribution Systems - Shutdown
LCO 3810 The necessary portion of AC DC and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE
APPLICABI LITY MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
ACTIONS
CONDITION
A One or more requiredAC DC or AC vital bus electrical powerdistribution systemsinoperable
REQUIRED ACTION
Al Declare associated supported required feature(s) inoperable
oR A2l
AND
Suspend CORE ALTERATIONS
A22 Suspend movement of fuel assemblies within containment
COMPLETION TIME
Immediately
Immediately
Immediately
A23
AND
Suspend movement of fuel assemblies in the fuel storage pool
A24 Suspend operationsinvolving positive reactivity additions that could result in loss of required SDM or boron concentration
Immediately
Immediately
(continued)
SAN ONOFRE--UNIT 3 38-40 Amendment No rtl219
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
Distribution Systems - Shutdown 3810
ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME
A (continued) A25 Initiate actions to restore required ACDC and AC vital bus electrical powerdistribution system(s) to OPERABLE status
Immediately
AND
A26 Declare associated required shutdown cooling systems)inoperable and not in operation
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 38101 Verify correct breaker alignments and voltage to required AC DC and AC vital bus electrical power distribution systems
7 days
SAN ONOFRE--UNIT 3 38-41 Amendment No ~219
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
Containment Penetrations 393
39 REFUELING OPERATIONS
393 Containment Penetrations
LCO 393 The containment penetrations shall be in the following status
a The equipment hatch closed and held in place by four bolts
-------------------------NOTE---------------------------- shyThe equipment hatch may be open if all of the following conditions are met I The Containment Structure Equipment Hatch Shield Doors
are capable of being closed within 30 minutes 2) The plant is in Mode 6 with at least 23 feet of water
above the reactor vessel flange3) A deSignated crew is available to close the Containment
Structure Equipment Hatch Shield Doors 4) Containment purge 1s in service and 5) The reactor has been subcritical for at least 72 hours
b One door in each air lock closed
-------------------------NOTE---------------------------- shyBoth doors of the containment personnel airlock may be open provided
a one personnel airlock door is OPERABLE and
bl the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or
b2 defueled configuration with fuel in containment (ie bullbull fuel in refueling machine or upender)
c Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either
1 closed by a manual or automatic isolation valve blind flange or eqUivalent or
2 capable of being closed by an OPERABLE Containment Purge System
APPLICABILITY During CORE ALTERATIONS During movement of fuel assemblies within containment
SAN ONOFRE--UNIT 3 39-4 Amendment No 184219
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
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Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
Containment Penetrations 393
ACTIONS
CONDITION REQUIRED ACTION COMPLETION TIME
A One or more AI containment penetrations not in required status AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3931 Verify each required containment penetration is in the required status
7 days
SR 3932 Verify each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal
24 months
SAN ONOFRE--UNIT 3 39-5 Amendment No plusmnplusmn6t219
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
Refueling Water Level 396
39 REFUELING OPERATIONS
396 Refueling Water Level
LCO 396 Refueling water level shall be maintained z 23 ft above the top of reactor vessel flange
-------------------------------------NOTE------------------------------------ shyWater level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling
APPLICABILITY During movement reactor pressure vessel Durin~ movement
of fuel
of fuel
assemblies
assemblies
or CEAs within the
within containment
ACTIONS
CONDITION REQUIRED ACTION COMPLET ION TIME
A Refueling water level not within limit
AI
AND
A2
Suspend CORE ALTERATIONS
Suspend movement of fuel assemblies within containment
Immediately
Immediately
SURVEILLANCE REQUIREMENTS
SURVEILLANCE FREQUENCY
SR 3961 The refueling water level shall be determined to be at least its minimum required depth
24 hours
SAN ONOFRE--UNIT 3 39-10 Amendment No tr3219
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
lINITED STATES NUCLEAR REGULATORY COMMISSION
WASHINGTON DC 20555-0001
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO 226 TO FACILITY OPERATING LICENSE NO NPF-10
AND AMENDMENT NO 219 TO FACILITY OPERATING LICENSE NO NPF-15
SOUTHERN CALIFORNIA EDISON COMPANY
SAN DIEGO GAS AND ELECTRIC COMPANY
THE CITY OF RIVERSIDE CALIFORNIA
SAN ONOFRE NUCLEAR GENERATING STATION UNITS 2 AND 3
DOCKET NOS 50-361 AND 50-362
10 INTRODUCTION
By application dated September 22011 (Agencywide Documents Access and Management System (ADAMS) Accession No ML 11252B110) Southern California Edison Company (the licensee) requested changes to the Technical Specifications (TSs) for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3
The licensees design-basis fuel handling accident (FHA) evaluation for SONGS shows that fuel damage may occur from dropping either a non-irradiated fuel assembly or an irradiated fuel assembly resulting in radiological consequences SONGS current TSs only address handling of irradiated fuel assemblies Because of this the licensee implemented administrative controls related to the movement of non-irradiated fuel assemblies in addition to the TS controls for movement of irradiated fuel assemblies Thus SONGS through the LAR proposes to change the TSs to include both irradiated and non-irradiated fuel assemblies The amendments would revise a number of TS requirements to impose additional restrictions to the movement of all fuel assemblies over irradiated fuel assemblies In addition as part of the LAR the NRC staff reviewed a new FHA evaluation for movement of fuel inside the fuel handling building and inside containment at SONGS 2 and 3
20 REGULATORY EVALUATION
21 Background
In Amendment No 210 to Facility Operating License (FOL) No NPF-10 for SONGS Unit 2 and Amendment No 202 to FOL No NPF-15 for SONGS Unit 3 issued December 29 2006
Enclosure 3
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
- 3shy
4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
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containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
- 2shy
(ADAMS Accession No ML063400359) the US Nuclear Regulatory Commission (NRC) approved a full-scope implementation of the alternative source term (AST) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 5067 Accident Source Term and following the guidance and methodology provided in applicable sections of NRC Regulatory Guide (RG) 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000 (ADAMS Accession No ML003716792) The NRC staff evaluated the proposed changes to the FHA to verify that the licensees postulated design basis radiological consequence analyses continue to meet the dose criteria listed in 10 CFR 5067
22 Regulatory Review Criteria
The proposed changes provide new applicability andor action language that include load movements over irradiated fuel assemblies The NRC staffs evaluation of the proposed changes is based upon the following regulations regulatory guides and standards
1 In 10 CFR 5036 Technical specifications the NRC established its regulatory requirements related to the content of TSs Pursuant to 10 CFR 5036 TSs are required to include items in the following five specific categories related to station operation (1) safety limits limiting safety system settings and limiting control settings (2) limiting conditions for operation (LCOs) (3) surveillance requirements (SRs) (4) design features and (5) administrative controls
bull 10 CFR 5036(b) states in part that the TSs will be derived from the analyses and evaluation included in the safety analysis report
bull 10 CFR 5036(c)(2)(ii) states in part that
A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria
(B) Criterion 2 A process variable design feature or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
(C) Criterion 3 A structure system or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier
2 10 CFR 5059 Changes tests and experiments
3 10 CFR 5067 Accident source term
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4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
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bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
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bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
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D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
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Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
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Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
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Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
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Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
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4 10 CFR Part 50 Appendix A General Design Criterion [GDG] for Nuclear Power Plants GDC 19 Control room
5 NRC RG 1183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors July 2000
6 Regulatory Guide 1187 Guidance for Implementation of 10 CFR 5059 Changes Tests and Experiments
7 NUREG-0800 Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants LWR Edition Section 64 Control Room Habitability Systems for control room (CR) dose Section 1574 Radiological Consequences of Fuel Handling Accidents and Section 1501 Radiological Consequence Analyses Using Alternative Source Terms
The applicable 10 CFR 5067 acceptance criteria are
bull 5 roentgen equivalent man (rem) total effective dose equivalent (TEDE) in the CR during the duration of the accident
bull 25 rem TEDE to an individual at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release and
bull 25 rem TEDE to an individual located at any point on the outer boundary of the low population zone (LPZ) who is exposed to the radioactive cloud resulting from the postulated fission product release during the entire period of its passage
RG 1183 and SRP 1501 provide additional guidance of 63 rem TEDE for FHAs for the exclusion area boundary (EAB) and LPZ for a 2 hour release
30 TECHNICAL EVALUATION
31 Description of Technical Specification Changes
The license amendment requested revising the following TSs
TS 338 Containment Purge Isolation Signal (CPIS) TS 339 Control Room Isolation Signal (CRIS) TS 3711 Control Room Emergency Air Cleanup System (CREACUS) TS 3716 Fuel Storage Pool Water Level TS 382 AC [Alternating Current] Sources - Shutdown TS 385 DC [Direct Current] Sources - Shutdown TS 388 Inverters - Shutdown TS 3810 Distribution Systems - Shutdown TS 393 Containment Penetrations TS 396 Refueling Water Level
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The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
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bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
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bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
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D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
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Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
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assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
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TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
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Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
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containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
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Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
-4shy
The proposed changes revise the applicability of these TSs to add a new specified condition to the Applicability statement The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word irradiated Conforming changes are made to the Actions portion of the TSs as appropriate
The following changes are proposed
bull LCO 338 Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised MODES 1 2 3 and 4 During CORE ALTERATIONS During movement of fuel assemblies within containment
Conforming change to delete irradiated from Condition 0 and from Required Action 022
bull LCO 339 Control Room Isolation Signal (CRIS)Containment Purge Isolation Signal (CPIS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition B to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pool Condition B22 is changed to delete irradiated and add within containment The following new Required Action B22 is added with an Immediately Completion Time
B22 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B22 is renumbered to B23 because of the addition of the above new Required Action
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
- 5shy
bull LCO 3711 Control Room Emergency Air Cleanup System (CREACUS)
Current MODES 1 2 3 4 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 1 2 3 4 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition 0 to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition 022 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
023 Suspend movement of fuel assemblies in the fuel storage pool
Conforming change are made to Condition E to delete irradiated and add within containment or during the movement of fuel assemblies in the fuel storage pooL Condition E22 is changed to delete irradiated and add within containment The following new Required Action E23 is added with an Immediately Completion Time
E23 Suspend movement of fuel assemblies in the fuel storage pool
bull LCO 3716 Fuel Storage Pool Water Level
Current During movement of irradiated fuel assemblies in the fuel storage pool
Revised During movement of fuel assemblies in the fuel storage pool
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
- 6 shy
bull LCO 382 AC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Irnmediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A2A are renumbered to A2A and A25 respectively because of the addition of the above new Required Action
Condition B2 is changed to delete irradiated and add within containment The following new Required Action B3 is added with an Immediately Completion Time
B3 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action B3 and BA are renumbered to BA and B5 respectively because of the addition of the above new Required Action
bull LCO 385 DC Sources - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition D22 is changed to delete irradiated and add within containment The following new Required Action D23 is added with an Immediately Completion Time
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
- 7 shy
D23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action D23 and D24 are renumbered to D24 and D25 respectively because of the addition of the above new Required Action
bull LCO 388 Inverters - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
Previous Required Action A23 and A24 are renumbered to A24 and A25 respectively because of the addition of the above new Required Action
bull LCO 3810 Distribution System - Shutdown
Current MODES 5 and 6 During movement of irradiated fuel assemblies
Revised MODES 5 and 6 During movement of fuel assemblies within containment During movement of fuel assemblies in the fuel storage pool
Condition A22 is changed to delete irradiated and add within containment The following new Required Action A23 is added with an Immediately Completion Time
A23 Suspend movement of fuel assemblies in the fuel storage pool
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
- 8 shy
Previous Required Action A23 A24 and A25 are renumbered to A24 A25 and A26 respectively because of the addition of the above new Required Action
bull LCO 393 Containment Penetrations
Current During CORE ALTERATIONS During movement of irradiated fuel assemblies within containment
Revised During CORE ALTERATIONS During movement of fuel assemblies within containment
bull LCO 396 Refueling Water Level
Current During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies being moved or the fuel assemblies seated within the reactor pressure vessel are irradiated During movement of irradiated fuel assemblies within containment
Revised During movement of fuel assemblies or CEAs within the reactor pressure vessel During movement of fuel assemblies within containment
32 NRC Staff Evaluation
321 Radiological Consequences
The SONGS final safety analysis report (FSAR) Section 157 Radioactive Release From a Subsystem or Component describes the design basis FHA analysis of record (AOR) that assumes that a fuel assembly drop occurs during movement of irradiated fuel assemblies within the fuel building andor reactor building The FHA is modeled as the dropping of a single fuel assembly and handling tool or of a heavy object onto other spent fuel assemblies The licensees proposed new FHA considers changes to two assumptions in the FHA AOR (1) the assumed number of fuel pins failed and (2) the assumed fuel bundle weight was increased as stated above The methodology and all other inputs parameters andor assumptions used in the radiological model remained unchanged and are consistent with the licensees current licensing basis and their previously approved AST amendment
The licensees updated analysis for an FHA inside the fuel handling building (FHA-FHS) predicts that a dropped irradiated fuel assembly would result in a failure of 472 irradiated fuel pins and that a new (non-irradiated) fuel assembly drop would result in a failure of 236 irradiated fuel pins These updated irradiated fuel pin failures are above the licensees current AOR value of 60 irradiated fuel pins failing for a FHA-FHB Similarly the licensees updated analysis for a FHA inside the containment (FHA-IC) assumes that a dropped irradiated fuel
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
- 9shy
assembly would result in a failure of 472 irradiated fuel pins This updated number is above the licensees current AOR value of 226 irradiated fuel pins failing for an FHA-IC The FHA-FHB is the more limiting analysis
The proposed change to the FHA alters the assumed fuel failure resulting from the postulated FHA Proposed TS changes related to the applicability andor actions regarding load movements over irradiated fuel assemblies in containment and in the fuel storage pool are reflective of the new FHA
RG 1183 Appendix B Assumptions for Evaluating the Radiological Consequences of a Fuel Handling Accident states in part that
The number of fuel rods damaged during the accident should be based on a conservative analysis that considers the most limiting case This analysis should consider parameters such as the weight of the dropped heavy load or the weight of a dropped fuel assembly (plus any attached handling grapples) the height of the drop and the compression torsion and shear stresses on the irradiated fuel rods Damage to adjacent fuel assemblies if applicable (eg events over the reactor vessel) should be considered
The licensee identified that the current FHA AOR did not include the use of heavier bundle weights nor the weights of components such as control element assemblies neutron source or handling grapples Additionally the fuel bundle weights used at the site have increased due to changes in fuel assembly design Therefore the licensee performed a revised analysis of a postulated FHA which included the heavier bundle weights weights of any additional components and a discretionary margin of 50 pounds (Ibs) which had not been accounted for in previous fuel assembly drop fuel rod failure analyses
For the fuel bundle drop scenarios in the fuel storage pool and core locations the licensees updated postulated FHA analysis assumes that all the fuel pins in both the dropped fuel assembly and the struck fuel assembly fail (472 pins total 236 pins per assembly) The licensees updated postulated FHA analysis assumes various fuel bundle weight combinations (bundlediscretionary weightgrapple weight) up to 2065 Ibs
The NRC staff conducted a quantitative analysis multiplying the current FHA-FHB AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-FHB to those in the current AOR (472 pins60 pins - an increase of a factor of 8) For the FHA-FHB exclusion area boundary (EAB) doses the results of the licensees analysis (ie doses going from 02 rem TEDE to 17 rem TEDE) are consistent with an increase of a factor of 8 Likewise the NRC staff conducted a quantitative analysis multiplying the current FHA-IC AOR doses by the ratio of assumed fuel pin failure in the proposed FHA-IC to those in the current AOR (472 pins226 pins - a doubling) For the FHA-IC EAB doses and for the FHA-IC control room (CR) doses the doubling of the doses is consistent with the licensees analysis (Le doses for the FHA-IC EAB case increasing from 08 rem TEDE to 17 rem TEDE and for the FHA-IC CR doses increasing from 03 rem TEDE to 06 rem TEDE)
Performing this numerical comparison for some of the FHA-FHB AOR values in the initial analysis is not possible because the initial analysis results are reported as less than 01 rem
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
- 10shy
TEDE This is the case for the following analysis FHA-FHB at the outer boundary of the low population zone (LPZ) FHA-FHB CR and FHA-IC LPZ The staff notes that by multiplying a value of less than 01 rem TEDE by a factor of 8 for the FHA-FHB cases and by a factor of 2 for the FHA-IC LPZ case will result in doses that are well within regulatory guidance limits found in RG 1183 and SRP 1501
The NRC staff also determined that the increase in the load to 2065 Ibs conservatively includes andor models the use of the heavier bundle and weights and the weights of components within the radiological analyses The NRC staff also considers the change in assumptions for the FHA-FHB and FHA-IC that the dropped fuel assembly falls on an irradiated fuel assembly and the pins (472 or 236 per assembly) in both the dropped and impacted fuel assemblies fail to be reasonable The staff concludes that the licensees analysis is consistent with the guidance found in RG 1183 because the assumed weight of the fuel assembly and the assumed number of fuel rods damaged during the accident are based on a conservative analysis that considers the most limiting case
NRC Approval of Changes to FHA-FHB and FHA-IC
The licensee identified that the changes to the radiological doses for the FHA-FHB require NRC approval Guidance in this area is provided in RG 1187 which endorses Revision 1 of NEI 96-07 Guidelines for 10 CFR 5059 Evaluations dated November 2000 NEI 96-07 provides criteria and examples of changes that result in more than a minimal increase in the consequences of an accident previously evaluated that would therefore require prior NRC approval in accordance with 10 CFR 5059(c)(2)(iii) A more than minimal increase in consequences from a proposed activity is defined as an increase that is greater than 10 percent of the difference between the current calculated dose value and the regulatory limit
The FHA-FHB CR dose increases by more than 10 of the difference between the current dose to the regulatory limit Ten percent of the difference for this case is 059 rem TEDE laquo50 remshy01 rem) x 10 + 01 rem = 49 rem x 10 + 01 rem =059 rem) The FHA-FHB CR dose is 06 rem TEDE which is greater than 059 rem Therefore the staff concludes that the change to the FHA-FHB CR dose is more than minimal and meets the requirement of 10 CFR 5059(c)(2)(iii) for requiring NRC prior approval The staff also concludes that because the revised dose is below the regulatory limit of 5 rem TEDE that the revised FHA-FHB CR dose of 06 rem TEDE is acceptable
Table 1 below contains a column that provides the value for the FHA-FHB and FHA-IC for the EAB LPZ and the CR that if exceeded trips the criteria of 10 CFR 5059(c)(2)(iii) of more than a minimal increase in the doses that would require NRC prior approval The table includes the regulatory limit found in 10 CFR 5067 and the regulatory guide value for these doses For purposes of the calculations to determine 10 of the difference the regulatory limit found in 10 CFR 5067 is used in accordance with the guidance found in NEI 96-07 For example the FHA-FHB EAB value that would result in more than a minimal increase is laquo25 rem-02 rem) x 10 +02 rem =248 rem x 10 + 02 rem =27 rem) The staff notes that based on the Table results below the FHA-FHB CR dose is the only dose that exceeds the more than a minimal increase value calculated in accordance with NEI 96-07 guidance The staff also notes that for all cases the proposed revised FHA dose values are less than the RG 1183 and SRP 1501 guidance
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
- 11 shy
Therefore the staff concludes that the FHA-FHB EAB FHA-FHB LPZ FHA-IC EAB FHA-IC LPZ and FHA-IC CR increase in doses do not exceed the values requiring prior NRC approval Nevertheless the staff reviewed the resulting change in doses for these cases and also concludes that because they are below the RG 1183 and SRP 1501 criteria that the revised doses are acceptable
TABLE 1 Comparison of the Radiological Consequence Results of Revised Postulated
Fuel Handling Accident at San Onofre Nuclear Generating Station (Limiting Case of 472 Pins Failed)
FHA Inside Fuel Handling Building
Baseline Case
(rem TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE) Exclusion Area Boundary (EAB)
02 17 27 63 25 i
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) lt01 06 059 50 5
FHA Inside Containment
Baseline Case (rem
TEDE)
Proposed Amendment (rem TEDE)
Value if Exceeded Requires
NRC approval
(rem TEDE)
RG 1183 and SRP 1501
Acceptance Criteria
(rem TEDE)
10 CFR 5067 limit
(rem TEDE)
Exclusion Area Boundary (EAB)
08 17 322 63 i
25
Low Population Zone (LPZ)
lt01 lt01 259 63 25
Control Room (CR) 03 06 077 50 5 I
322 Evaluation of Technical Specification Changes
The previous version of the TSs was based on movement of irradiated fuel only Because of the changes in assumptions for the FHA-FHB and the FHA-IC discussed above the NRC staff agrees with the licensee that changes to appropriate TSs are necessary for the reasons described below
The licensee proposed changes to TSs 338339371137163823853883810 393 and 396 to conform with the assumptions of the revised FHA The staff finds the TS changes ensure compliance with regulations for the following reasons
bull TS 338 Containment Purge Isolation Signal (CPIS) generates a train related containment purge isolation signal upon detection of high gaseous radiation in
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
- 12 shy
containment to help to minimize the escape of fission products in the event of a FHA-IC The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CPIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a limiting condition for operation (LCD) in the TSs Therefore the CPIS must be operable when needed Prohibiting fuel movement when the CPIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 339 Control Room Isolation Signal (CRIS) terminates the normal supply of outside air to the control room and initiates actuation of the control room emergency air cleanup system to minimize operator radiation exposure in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CRIS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCD in the TSs Therefore the CRIS must be operable when needed Prohibiting fuel movement when the CRIS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3711 Control Room Emergency Air Cleanup System (CREACUS) consists of two independent redundant trains that recirculate and filter air in the control room envelope and control room envelope boundary that limits the inleakage of unfiltered air helping to protect control room personnel in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The CREACUS is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)ii)(C) for a LCD in the TSs Therefore the CREACUS must be operable when needed Prohibiting fuel movement when the CREACUS is inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 3716 Fuel Storage Pool Water Level establishes a minimum water level in the fuel storage pool to be consistent with the assumptions of iodine decontamination factors following a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The fuel storage pool water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(8) for inclusion in the TSs Therefore the fuel storage pool water level must be maintained when needed Prohibiting fuel movement when the fuel storage pool water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 382 AC Sources Shutdown TS 38S DC Source - Shutdown TS 388 Inverters-Shutdown TS 3810 Distribution Systems - Shutdown ensure that adequate electrical power is provided to mitigate events postulated during shutdown such as a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The AC Sources - Shutdown DC
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
- 13shy
Sources - Shutdown Inverters - Shutdown and Distribution Systems - Shutdown are credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for LCOs in the TSs Therefore the AC Sources - Shutdown DC Sources - Shutdown InvertersshyShutdown and Distribution Systems - Shutdown must be operable when needed Prohibiting fuel movement when these systems are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 393 Containment Penetrations limits the consequences of a FHA in containment by limiting the potential escape paths for fission product radioactivity released within containment The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The Containment Penetrations system is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(C) for a LCO in the TSs Therefore the Containment Penetrations must be operable when needed Prohibiting fuel movement when the Containment Penetrations are inoperable assures that the performance levels of equipment required for safe operation of the plant is maintained
bull TS 396 Refueling Water level establishes a water level that is used as an initial condition design parameter in the analysis for the FHA in containment and allows a decontamination factor of 100 to be used in the accident analysis for iodine in the event of a FHA The revised FHA assumes that movement of non-irradiated fuel assemblies over irradiated fuel can cause a FHA The refueling water level is an operating restriction that is credited in mitigating the FHA which is a design basis accident found in FSAR Section 1S7 and meets the requirements of 10 CFR SO36(c)(2)(ii)(B) for inclusion in the TSs Therefore the refueling water level must be maintained when needed Prohibiting fuel movement when the refueling water level is lower than the minimum water level assures that the performance levels of equipment required for safe operation of the plant is maintained
Based on the above the NRC staff concludes that the proposed TS changes to TSs 338 33937113716382 38S 388 3810 393 and 396 are in compliance with the requirements of 10 CFR SO36 Therefore the NRC staff concludes that the proposed changes are acceptable
40 STATE CONSULTATION
In accordance with the Commissions regulations the California State official was notified of the proposed issuance of the amendment The State official had no comments
SO ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure The
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
- 14shy
Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no public comment on such finding published in the Federal Register on December 13 2011 (76 FR 77572) Accordingly the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 5122(c)(9) Pursuant to 10 CFR 5122(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments
60 CONCLUSION
The NRC staff has concluded based on the considerations discussed above that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public
Principal Contributor LaRay J Benton Joseph M Sebrosky
Date October 16 2012
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY
October 16 2012 Mr Peter T Dietrich Senior Vice President and Chief Nuclear Officer Southern California Edison Company San Onofre Nuclear Generating Station PO Box 128 San Clemente CA 92674-0128
SUBJECT SAN ONOFRE GENERATING STATION UNITS 2 AND 3 -ISSUANCE OF AMENDMENTS RE REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS APPLICABLE TO MOVEMENT OF FUEL ASSEMBLIES (TAC NOS ME7090 AND ME7091)
Dear Mr Dietrich
The US Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No 226 to Facility Operating License No NPF-10 and Amendment No 219 to Facility Operating License No NPF-15 for San Onofre Nuclear Generating Station Units 2 and 3 respectively This amendment consists of changes to the Technical Specifications (TSs) in response to your application dated September 2 2011
The amendments revise a number of TS requirements to impose similar restrictions on the movement of non-irradiated fuel assemblies to those currently in place for movement of irradiated fuel assemblies The additional restrictions will limit the movement of all fuel assemblies over irradiated fuel assemblies in containment or in the fuel storage pool
A copy of our related Safety Evaluation is also enclosed The Notice of Issuance will be included in the Commissions next biweekly Federal Register notice
Sincerely IRA
Joseph M Sebrosky Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Docket Nos 50-361 and 50-362
Enclosures 1 Amendment No 226 to NPF-1 0 2 Amendment No 219 to NPF-15 3 Safety Evaluation
cc wencls Distribution via Listserv DISTRIBUTION PUBLIC RidsNrrDraAadb Resource RidsRgn4MailCenter Resource LPLIV rtf RidsNrrDssSbpb Resource S50m NRRlDElEEEB RidsAcrsAcnw MailCTR Resource RidsNrrDssScvb Resource SMazumdar NRRlDEEICB RidsNrrDeEeeb Resource RidsNrrDssStsb Resource LBenton NRRlDRAlAADB RidsNrrDeEicb Resource RidsNrrLAJBuiKhardt Resource KBucholtz NRRlDSSSTSB RidsNrrDoriDpr Resource RidsNrrPM5anOnofre Resource OHopkins NRRlDSSSBPB RidsNrrDorlLpl4 Resource RidsOgcRp Resource RTorres NRRlDSSSCVB
ADAMS Accession No ML12215A399 OFFICE
NAME
NRRlLPL4PM ~LJSebrosky
PL4LA rkhardt
NRRlDEEEEBBC NRRlDEEICBBC
JThorp
NRRlDRAlAADBBC
TTate (lDozier for)
NRRlDSSSBPBIBC
GCasto
DATE 103112 8117112 82712 82312 10312 812112
OFFICE NRRlDSSSCVBBC NRRlDSSSTSBBC OGC NLO NRRlLPL4BC NRRlLPL4PM
NAME HWalker RElliott DRoth MMaiKley JSebrosky
DATE 82112 82412 10912 1011612 101612
OFFICIAL RECORD COPY