ML050380403

Proposed Change Number (PCN) 552, Request to Revise Technical Specification 3.6.3, Containment Isolation Valves.

ML050380403
Person / Time
Site:	San Onofre
Issue date:	02/03/2005
From:	Nunn D Southern California Edison Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NUREG-1432, Rev 3
Download: ML050380403 (33)

Text

SOUTHERN CALIFORNIA E>IDa Dwight 1 E. Nunn EDISON) Vice President An EDISON INTERNATIONALO Company February 3, 2005 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Docket Numbers 50-361 and 50-362 Proposed Change Number (PCN) 552 Request to Revise Technical Specification 3.6.3, "Containment Isolation Valves."

San Onofre Nuclear Generating Station Units 2 and 3 Gentlemen:

Pursuant to 10 CFR 50.90, Southern California Edison (SCE) hereby requests the following amendment to Facility Operating Licenses NPF-10 and NPF-15 for San Onofre Units 2 and 3, respectively: In Technical Specification (TS) 3.6.3, "Containment Isolation Valves," revise Surveillance Requirements (SRs) 3.6.3.3 and 3.6.3.4 to specify that only containment isolation valves which are not locked, sealed, or otherwise secured are required to be verified closed. This change will potentially reduce the occupational dose received while performing these surveillances. The proposed change is consistent with the Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-45, Revision 2, 'Exempt verification of ClVs (containment isolation valves) that are not locked, sealed, or otherwise secured," and 'Standard Technical Specifications, Combustion Engineering Plants," NUREG-1432, Revision 3.

SCE has evaluated this request under the standards set forth in 10 CFR 50.92(c) and determined that a finding of 'no significant hazards consideration" is justified.

SCE requests that these amendments be implemented within 60 days from the date of issuance.

SCE is making no new commitments that would result from NRC approval of the proposed amendments.

P.O. Box 128 San Clemente. CA 92674-0128 949-368-1480 Fax 949-368-1490

Document Control Desk February 3, 2005 If you have any questions or require additional information, please contact Mr. Jack Rainsberry at (949) 368-7420.

Sincerely, Enclosures

1. Notarized Affidavits

2. Licensee's Evaluation of the Proposed Change Attachments:

Existing Technical Specification page, Unit 2 Existing Technical Specification page, Unit 3 Markup of Technical Specification page, Unit 2 Markup of Technical Specification page, Unit 3 Retyped Technical Specification page, Unit 2 Retyped Technical Specification page, Unit 3 G. Markup of Bases Changes, Unit 2 cc: B. S. Mallett, Regional Administrator, NRC Region IV B. M. Pham, NRC Project Manager, San Onofre Units 2 and 3 C. C. Osterholtz, NRC Senior Resident Inspector, San Onofre Units 2 and 3 S. Y. Hsu, Department of Health Services, Radiologic Health Branch

Enclosure 1 Page 1 of 2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA )

EDISON COMPANY, ET AL. for a Class 103 ) Docket No. 50-361 License to Acquire, Possess, and Use a )

Utilization Facility as Part of Unit No.2 of the ) Amendment Application No. 232 San Onofre Nuclear Generating Station )

SOUTHERN CALIFORNIA EDISON COMPANY, et al., pursuant to 10CFR50.90, hereby submit Amendment Application No. 232. This amendment application consists of Proposed Change Number (PCN) 552 to Facility Operating License NPF-10. PCN-552 is a request to revise Technical Specification (TS) 3.6.3, "Containment Isolation Valves," Surveillance Requirements (SRs) 3.6.3.3 and 3.6.3.4 to specify that only containment isolation valves which are not locked, sealed, or otherwise secured are required to be verified closed for San Onofre Nuclear Generating Station Unit 2.

State of California County of San Diego Dwight E. Nunn, Ale President ybscribed and sworn to (or affirmed) before me on this day of TJ1~AI ,H6 , by ki}'ambrMt personally known to me r _ t o to be the person who appeared before me.

Notay Pi 1 Cr 1n3c75470 Notary Publicm

Enclosure I Page 2 of 2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA )

EDISON COMPANY, ETAL. fora Class 103 ) Docket No. 50-362 License to Acquire, Possess, and Use a )

Utilization Facility as Part of Unit No. 3 of the ) Amendment Application No. 216 San Onofre Nuclear Generating Station )

SOUTHERN CALIFORNIA EDISON COMPANY, et al., pursuant to IOCFR50.90, hereby submit Amendment Application No. 216. This amendment application consists of Proposed Change Number (PCN) 552 to Facility Operating License NPF-15. PCN-552 is a request to revise Technical Specification (TS) 3.6.3, "Containment Isolation Valves," Surveillance Requirements (SRs) 3.6.3.3 and 3.6.3.4 to specify that only containment isolation valves which are not locked, sealed, or otherwise secured are required to be verified closed for San Onofre Nuclear Generating Station Unit 3.

State of California County of San Diego Dwight E. Nunn, ce President d Subscribed and sworn to (or affirmed) before me this _ __ day of 0

_, 2005, by_ __)

L_

i jtinl Is personally known to me or prmvei to mP nn the basis of s kaiactor' ovise to be the person who appeared before me.

l SANCHZ1375470 a NotaryPubic-C nfflI otary Public

ENCLOSURE 2 LICENSEE'S EVALUATION Proposed Change Number 552

SUBJECT:

Technical Specification 3.6.3, "Containment Isolation Valves," Revise Surveillance Requirements 3.6.3.3 and 3.6.3.4 to Specify That Only Containment Isolation Valves Which Are Not Locked, Sealed, or Otherwise Secured Are Required To Be Verified Closed

2.0 DESCRIPTION

OF PROPOSED AMENDMENT

3.0 BACKGROUND

4.0 REGULATORY REQUIREMENTS AND GUIDANCE

6.0 REGULATORY ANALYSIS

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION 8.0 PRECEDENCES

10.0 REFERENCES

ATTACHMENTS:

A. Existing Technical Specification page, Unit 2 B. Existing Technical Specification page, Unit 3 C. Markup of Technical Specification page, Unit 2 D. Markup of Technical Specification page, Unit 3 E. Retyped Technical Specification page, Unit 2 F. Retyped Technical Specification page, Unit 3 G. Markup of Bases Changes, Unit 2 i

LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENTS FOR LOCKED, SEALED, OR OTHERWISE SECURED CONTAINMENT ISOLATION VALVES (SRs 3.6.3.3 and 3.6.3.4)

San Onofre Nuclear Generating Station, Units 2 and 3

1.0 INTRODUCTION

This letter is a request to amend Operating Licenses NPF-1 0 and NPF-15 for San Onofre Nuclear Generating Station (SONGS), Units 2 and 3, respectively.

The proposed change would revise Technical Specification 3.6.3, "Containment Isolation Valves," Surveillance Requirements (SRs) 3.6.3.3 and 3.6.3.4 for Containment Isolation Valves and Blind Flanges (ClVs) by adding a provision to exempt CIVs that are locked, sealed, or otherwise secured from the position verification surveillance requirements.

2.0 DESCRIPTION

OF PROPOSED AMENDMENT This proposed change will revise Technical Specification 3.6.3, "Containment Isolation Valves," SRs 3.6.3.3 and 3.6.3.4 to exempt locked, sealed, or otherwise secured CIVs from the requirements 1) to verify outside containment CIVs closed'on a 31-day frequency and 2) to verify inside containment CIVs closed prior to entering Mode 4 from Mode 5 if not performed within the previous 92 days, as stated below. The proposed change is consistent with the Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF)

Standard Technical Specification Change Traveler, TSTF-45, Revision 2, "Exempt verification of CIVs (containment isolation valves) that are not locked, sealed, or otherwise secured," (Reference 1) and "Standard Technical Specifications, Combustion Engineering Plants," NUREG-1432, Revision 3 (Reference 2).

EXISTING TECHNICAL SPECIFICATIONS:

Unit 2: See Attachment A Unit 3: See Attachment B PROPOSED TECHNICAL SPECIFICATIONS (Additions highlighted and deletions struck-out)

Unit 2: See Attachment C Unit 3: See Attachment D

2 PROPOSED TECHNICAL SPECIFICATIONS (with changes)

Unit 2: See Attachment E Unit 3: See Attachment F The Technical Specification Bases for SRs 3.6.3.3 and 3.6.3.4 will be revised to include a statement that the SR does not apply to valves and blind flanges that are locked, sealed, or otherwise secured in the closed position, since these were verified to be in the correct position upon locking, sealing, or securing. The Bases changes for Unit 2 are provided for information only (See Attachment G).

3.0 BACKGROUND

The SONGS Units 2 and 3 Updated Final Safety Analysis Report, (Sections 3.1.2.7, 3.1.5.1, 3.1.5.5, and 6.2.1.1.1) (Reference 3) indicates that Containment is designed to limit the release to the environs of radioactive materials resulting from Design Basis Accidents (DBAs) so that off-site doses will be below the values stated in 10 CFR 100, and Control Room occupant doses are within the limits of General Design Criterion (GDC) 19.

CIVs form a part of the containment boundary. The function of the CIVs, in combination with other accident mitigation systems, is to limit fission product release during and following the postulated DBAs. The CIVs help ensure that an adequate containment boundary is maintained during and after an accident by minimizing potential paths to the environment. This proposed change will potentially reduce the occupational dose received by SONGS Units 2 and 3 Operations personnel while conducting these surveillances.

4.0 REGULATORY REQUIREMENTS AND GUIDANCE Containment is designed to limit the release to the environs of radioactive materials resulting from design basis accidents as required by GDC 16 so that off-site doses will be below the values stated in 10 CFR 100, and Control Room occupant doses are within the limits of GDC 19. The CIVs consist of either passive devices or active (automatic) devices. Manual valves, de-activated automatic valves secured in their closed position (including check valves with flow through the valve secured), and blind flanges are considered passive devices. These passive devices are considered operable when manual valves are closed or open in accordance with appropriate administrative controls, automatic CIVs are de-activated and secured in their closed position, and blind flanges are in place as verified by SRs 3.6.3.3 and 3.6.3.4.

3 The proposed change credits the fact that the ClVs that are locked, sealed, or secured were verified to be in the proper position at the time of locking, sealing, or otherwise securing. This change is consistent with the NRC approved Industry/TSTF Standard Technical Specification Change Traveler, TSTF-45, Revision 2, "Exempt verification of CIVs that are not locked, sealed or otherwise secured," and "Standard Technical Specifications, Combustion Engineering Plants," NUREG-1432, Revisions 2 and 3.

5.0 TECHNICAL ANALYSIS

The Design Basis of the ClVs is not affected by the proposed change to the surveillance requirements. The locked, sealed, or otherwise secured ClVs are verified to be closed at the time they are locked, sealed, or otherwise secured and are administratively controlled to remain in the required position. Thus, exempting these CIVs from the requirement to be verified in the correct position during the "31-day" surveillance (SR 3.6.3.3) and during the "Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" surveillance (SR 3.6.3.4) will not significantly reduce the assurance that the blind flanges and valves are in the closed/

correct position and will not affect the ability of these components to perform their design function.

6.0 REGULATORY ANALYSIS

Locked, sealed, or otherwise secured valves and blind flanges will be exempted from the requirement that ClVs be demonstrated operable by verification of their position under SRs 3.6.3.3 and 3.6.3.4. The ClVs form a part of the Containment boundary which is designed to limit the release to the environs of radioactive materials resulting from a design basis accident to maintain the off-site doses below the values stated in 10 CFR 100 and Control Room occupant doses within the limits of GDC 19. The locked, sealed, or otherwise secured valves will remain operable since they were verified to be in the proper position when locking, sealing, or otherwise securing them. Administrative controls govern position verification for locked, sealed, or otherwise secured valves and blind flanges such that there is a very low probability that unacceptable alignment can occur. No ClVs were found to be out of position from a review of all the San Onofre Units 2 and 3 surveillance data from January 2000 through December 2004.

7.0 NO SIGNIFICANT HAZARDS CONSIDERATION 10 CFR 50.91 (a)(1) requires that licensee requests for operating license amendments be accompanied by an evaluation of significant hazard posed by issuance of an amendment. Southern California Edison (SCE) has evaluated this proposed amendment with respect to the criteria

4 given in 10 CFR 50.92 (c).

The proposed change to the San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 Technical Specifications (TS) would add a provision to exempt locked, sealed, or otherwise secured Containment Isolation Valves and Blind Flanges (ClVs) from the "31-day" and "Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" position verification surveillance requirements. This change is consistent with the Nuclear Regulatory Commission (NRC) approved Industry Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler, TSTF-45, Revision 2, "Exempt verification of (Containment Isolation Valves) ClVs that are not locked, sealed, or otherwise secured," and "Standard Technical Specifications, Combustion Engineering Plants," NUREG-1432, Revisions 2 and 3.

1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

The proposed change does not affect the CIV design or function. In addition, mis-positioned or failed ClVs are not the initiator of any event. The position of a locked, sealed, or otherwise secured valve and blind flange is verified at the time it is locked, sealed, or secured, and these ClVs are administratively controlled to remain in the required position. Further, since the change impacts only the re-verification of the blind flange and valve position as a Technical Specification Surveillance, it does not result in any change in the response of the equipment to an accident.

Based on the above, SCE concludes that deleting the re-verification of the position of a locked, sealed, or secured CIV as a Technical Specification Surveillance does not affect the probability or consequences of an accident previously evaluated.

2. Do the proposed changes create the possibilityof a new kind of accident from any accident previously evaluated?

This change does not add any new equipment or result in any changes to equipment design or capabilities. This change also does not result in any changes to the operation of the plant. The position of a locked, sealed, or otherwise secured blind flange and valve is verified at the time it is locked, sealed, or secured, and these ClVs are administratively controlled to remain in the required position. Further, since the change impacts only the re-verification of the blind flange and valve position as a Technical Specification Surveillance, it does

5 not result in any change in the response of the equipment to an accident.

Based on the above, SCE concludes that deleting the re-verification of the position of a locked, sealed, or secured CIV as a Technical Specification Surveillance does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Do the proposed changes involve a significant reduction in a margin of safety?

The CIVs are administratively controlled and their operation is a non-routine event. The position of a locked, sealed, or otherwise secured blind flange and valve is verified at the time it is locked, sealed, or secured. Also, no CIVs were found to be out of position from a review of all the San Onofre Units 2 and 3 surveillance data from January 2000 through December 2004. Since the change only deletes the re-verification of the blind flange and valve position as a Technical Specification Surveillance and the administrative controls are in place, the proposed change will provide a similar level of assurance of correct CIV position as the current verifications.

Based on the above, SCE concludes that deleting the re-verification of the position of a locked, sealed, or secured CIV as a Technical Specification Surveillance does not involve a significant reduction in a margin of safety.

From the above discussions, SCE concludes that the proposed amendment involves no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

8.0 PRECEDENTS Similar amendments have been granted by the NRC for Sequoyah Nuclear Plant (SQN) Unit 1, Docket No. 50-327, License No. DPR-77, Amendment No. 271; SQN Unit 2, Docket No. 50-328, License No. DPR-79, Amendment No. 260, dated October 24, 2001; Cooper Nuclear Station (CNS), Docket No. 50-298, License No. DPR-46, Amendment No. 202, dated December 5, 2003; and Arkansas Nuclear One, Unit 2, Docket No.

50-368, License No. NPF-6, Amendment No. 252, dated December 4, 2003.

Provisions to exempt Containment Isolation Valves (CIVs) that are locked, sealed, or otherwise secured from the Technical Specification requirement to verify correct valve position is in accordance with current San Onofre Units 2 and 3 Surveillance Requirements (SRs) 3.5.2.3 (Emergency Core Cooling valves), 3.7.5.1 (Auxiliary Feedwater valves), and 3.7.8.1 (Salt

6 Water Cooling valves). These three current SRs were incorporated into the original SONGS Units 2 and 3 Technical Specifications (Reference 4) consistent with NUREG-0212, Revision 2, issued Fall 1980 (Reference 5),

and Revision 0 of NUREG 1432,.dated September 1992 (Reference 6).

TSTF-45, Revision 2, which incorporated a similar exemption for Containment Isolation Valves that are locked, sealed, or otherwise secured, was subsequently approved by the NRC on July 26,1999 and included in Revisions 2 and 3 to NUREG 1432, dated June 2001 and June 2004, respectively (References 7 and 2). The proposed change to the SONGS TS will make them consistent with the appropriate section of NUREG 1432, Revisions 2 and 3.

9.0 ENVIRONMENTAL CONSIDERATION

10 CFR 51.22(b) allows that an environmental assessment (EA) or an environmental impact statement (EIS) is not required for any action included in the list of categorical exclusions in 10 CFR 51.22(c). 10 CFR 51.22(c)(9) identifies an amendment to an operating license which changes a requirement with respect to installation or use of a facility component located within the restricted area, or which changes an inspection or a surveillance requirement, as a categorical exclusion if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration, (2) result in a significant change in the types or significant increase in the amount of any effluents that may be released off-site, or (3) result in an increase in individual or cumulative occupational radiation exposure.

SCE has reviewed the proposed license amendment and concludes that it meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(c), no environmental impact statement or environmental assessment needs to be prepared in connection with issuance of the proposed license changes. The basis for this determination is as follows:

1. The proposed license amendment does not involve significant hazards as described previously in the No Significant Hazards Consideration Evaluation.

2. This proposed change does not result in a significant change in the types or significant increase in the amounts of any effluents that may be released off-site. The proposed license amendment does not introduce any new equipment, nor does it require any existing equipment or systems to perform a different type of function than they are presently designed to perform. SCE has concluded that there will not be a significant increase in the types or amounts of any effluents that may be released off-site and these changes do not involve irreversible environmental consequences beyond those already associated with normal operation.

7

3. This change does not adversely affect plant systems or operation and therefore, does not significantly increase individual or cumulative occupational radiation exposure beyond that already associated with normal operation.

10.0 REFERENCES

1. TSTF-45, Revision 2, "Exempt verification of ClVs that are not locked, sealed, or otherwise secured," approved July 26, 1999

2. NUREG-1432, Standard Technical Specifications Combustion Engineering Plants, Revision 3, dated June 2004

3. San Onofre Units 2 and 3 Updated Final Safety Analysis Report (UFSAR), Section 3.1.2.7 Criterion 16 - Containment Design, Section 3.1.5.1 Criterion 50 - Containment Design Basis, Section 3.1.5.5 Criterion 54- Pining Systems Penetratinq Containment, and Section 6.2.1.1.1 Containment Structure Design Bases

4. Operating Licenses NPF-10 and NPF-15 for the San Onofre Nuclear Generating Station, Units 2 and 3, respectively, dated February 16,1982 and November 15,1982

5. NUREG-0212, Revision 2, "Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors," issued Fall 1980.

6. NUREG-1432, Standard Technical Specifications Combustion Engineering Plants, Revision 0, dated September 1992

7. NUREG-1432, Standard Technical Specifications Combustion Engineering Plants, Revision 2, dated June 2001 PCN-552 Secured CIVsRev5

PCN-552 ATTACHMENT A Existing Technical Specification Pages San Onofre Unit 2

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS

---

NOTE-------------_-_-_-_

Section A, B, C, D, and E isolation valves are located in the LCS.

SURVEILLANCE FREQUENCY SR 3.6.3.1 Verify each 42 inch purge valve is sealed 31 days closed except for one purge valve in a penetration flow path while in Condition D of this LCO.

SR 3.6.3.2 Verify each 8 inch purge valve is closed 31 days except when the 8 inch purge valves are open for pressure control, ALARA or air quality considerations for personnel entry, or for Surveillances that require the valves to be open.

SR 3.6.3.3 -------------------NOTES--------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. SR 3.0.4 is not applicable Verify each containment isolation manual valve 31 days and blind flange that is located outside containment and is required to be closed during accident conditions is closed, except for containment isolation valves that are open under administrative controls.

(continued)

SAN ONOFRE--UNIT 2 3.6-13 Amendment No. 127

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.3.4 - -------------- NOTES--------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. SR 3.0.4 is not applicable.

Verify each containment isolation manual valve Prior to and blind flange that is located inside entering MODE 4 containment and required to be closed during from MODE 5 if accident conditions is closed, except for not performed containment isolation valves that are open within the under administrative controls. previous 92 days SR 3.6.3.5 Verify the isolation time of each Section A In accordance and B power operated and each automatic with the containment isolation valve is within limits. Inservice Testing Program SR 3.6.3.6 ------------------NOTES---------------------

Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.

Perform leakage rate testing for containment 184 days purge valves with resilient seals.

AND Within 92 days after opening the valve (continued)

SAN ONOFRE--UNIT 2 3.6-14 Amendment No. 1-2*,144

PCN-552 ATTACHMENT B Existing Technical Specification Pages San Onofre Unit 3

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS

---

NOTE-------------------------------------

Section A, B, C, D, and E isolation valves are located in the LCS.

SURVEILLANCE FREQUENCY SR 3.6.3.1 Verify each 42 inch purge valve is sealed 31 days closed except for one purge valve in a penetration flow path while in Condition D of this LCO.

SR 3.6.3.2 Verify each 8 inch purge valve is closed 31 days except when the 8 inch purge valves are open for pressure control, ALARA or air quality considerations for personnel entry, or for Surveillances that require the valves to be open.

SR 3.6.3.3 -------------------NOTES--------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. SR 3.0.4 is not applicable Verify each containment isolation manual valve 31 days and blind flange that is located outside containment and is required to be closed during accident conditions is closed, except for containment isolation valves that are open under administrative controls.

(continued)

SAN ONOFRE--UNIT 3 3.6-13 Amendment No. 116

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.3.4 ------------------NOTES--------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. SR 3.0.4 is not applicable.

Verify each containment isolation manual valve Prior to and blind flange that is located inside entering MODE 4 containment and required to be closed during from MODE 5 if accident conditions is closed, except for not performed containment isolation valves that are open within the under administrative controls. previous 92 days SR 3.6.3.5 Verify the isolation time of each Section A In accordance and B power operated and each automatic with the containment isolation valve is within limits. Inservice Testing Program SR 3.6.3.6 ------------------NOTES---------------------

Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1 I Perform leakage rate testing for containment 184 days purge valves with resilient seals.

AND Within 92 days after opening the valve (continued)

SAN ONOFRE--UNIT 3 3.6-14 Amendment No. 6,135

PCN-552 ATTACHMENT C Proposed Technical Specification Pages (Redline and Strikeout)

San Onofre Unit 2

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS

---

NOTE------------- _-_-_-_- _-_

Section A, B, C, D, and E isolation valves are located in the LCS.

SURVEILLANCE FREQUENCY SR 3.6.3.1 Verify each 42 inch purge valve is sealed 31 days closed except for one purge valve in a penetration flow path while in Condition D of this LCO.

SR 3.6.3.2 Verify each 8 inch purge valve is closed 31 days except when the 8 inch purge valves are open for pressure control, ALARA or air quality considerations for personnel entry, or for Surveillances that require the valves to be open.

SR 3.6.3.3 -------------------NOTES--------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. SR 3.0.4 is not applicable Verify each containment isolation manual valve and blind flange that is located outside days containment 'and not locked, sealed, or otherwise secured and is required to be closed during accident conditions is closed, except for containment isolation valves that are open under administrative controls.

(continued)

SAN ONOFRE--UNIT 2 3.6-13 Amendment No. 127T

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.3.4 ------------------NOTES--------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. SR 3.0.4 is not applicable.

Prior to entering MODE 4 Verify each containment isolation manual valve from MODE 5 if and blind flanje that is located inside not performed containment and not' locked,- sealed, or within the previous otherwise secured and required to be closed 92 days during accident conditions is closed, except for containment isolation valves that are open under administrative controls.

SR 3.6.3.5 Verify the isolation time of each Section A In accordance and B power operated and each automatic with the containment isolation valve is within limits. Inservice Testing Program SR 3.6.3.6 ------------------NOTES---------------------

Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.

Perform leakage rate testing for containment 184 days purge valves with resilient seals.

AND Within 92 days after opening the valve (continued)

SAN ONOFRE--UNIT 2 3.6-14 Amendment No. 127,144

PCN-552 ATTACHMENT D Proposed Technical Specification Pages (Redline and Strikeout)

San Onofre Unit 3

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS

---

NOTE-------------------------------------

Section A, B, C, D, and E isolation valves are located in the LCS.

SURVEILLANCE FREQUENCY SR 3.6.3.1 Verify each 42 inch purge valve is sealed 31 days closed except for one purge valve in a penetration flow path while in Condition D of this LCO.

SR 3.6.3.2 Verify each 8 inch purge valve is closed 31 days except when the 8 inch purge valves are open for pressure control, ALARA or air quality considerations for personnel entry, or for Surveillances that require the valves to be open.

SR 3.6.3.3 -------------------NOTES--------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. SR 3.0.4 is not applicable Verify each containment isolation manual valve and blind flange that_is located outside containment and'not.locked,'sealed, or 31 days btherwise secured and is required to be closed during accident conditions is closed, except for containment isolation valves that are open under administrative controls.

(continued)

SAN ONOFRE--UNIT 3 3.6-13 Amendment No. 44.6

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4

SR 3.6.3.4 ------------------NOTES--------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. SR 3.0.4 is not applicable.

Verify each containment isolation manual valve and blind flange that is located inside Prior to containment and not locked, sealed, or entering MODE 4 otherwise secured and required to be closed from MODE 5 if during accident conditions is closed, except not performed for containment isolation valves that are open within the under administrative controls. previous 92 days SR 3.6.3.5 Verify the isolation time of each Section A In accordance and B power operated and each automatic with the containment isolation valve is within limits. Inservice Testing Program SR 3.6.3.6 ------------------NOTES---------------------

Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1 Perform leakage rate testing for containment 184 days purge valves with resilient seals.

AND Within 92 days after opening the valve (continued)

SAN ONOFRE--UNIT 3 3.6-14 Amendment No. 116,135

PCN-552 ATTACHMENT E Proposed Technical Specification Pages San Onofre Unit 2

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS

---

NOTE-------------------------------------

Section A, B, C, D, and E isolation valves are located in the LCS.

SURVEILLANCE FREQUENCY SR 3.6.3.1 Verify each 42 inch purge valve is sealed 31 days closed except for one purge valve in a penetration flow path while in Condition D of this LCO.

SR 3.6.3.2 Verify each 8 inch purge valve is closed 31 days except when the 8 inch purge valves are open for pressure control, ALARA or air quality considerations for personnel entry, or for Surveillances that require the valves to be open.

SR 3.6.3.3 ------------------- NOTES--------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. SR 3.0.4 is not applicable Verify each containment isolation manual valve 31 days and blind flange that is located outside containment and not locked, sealed, or otherwise secured and is required to be closed during accident conditions is closed, except I

for containment isolation valves that are open under administrative controls.

(continued)

SAN ONOFRE--UNIT 2 3.6-13 Amendment No.

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.3.4 ------------------NOTES--------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. SR 3.0.4 is not applicable.

Verify each containment isolation manual valve Prior to and blind flange that is located inside entering MODE 4 containment and not locked, sealed, or from MODE 5 if otherwise secured and required to be closed not performed during accident conditions is closed, except within the for containment isolation valves that are open previous under administrative controls. 92 days SR 3.6.3.5 Verify the isolation time of each Section A In accordance and B power operated and each automatic with the containment isolation valve is within limits. Inservice Testing Program SR 3.6.3.6 ------------------NOTES---------------------

Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1.

Perform leakage rate testing for containment 184 days purge valves with resilient seals.

AND Within 92 days after opening the valve (continued)

SAN ONOFRE--UNIT 2 3.6-14 .Amendment No.

PCN-552 ATTACHMENT F Proposed Technical Specification Pages San Onofre Unit 3

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS

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NOTE-------------_ -_

Section A, B, C, D, and E isolation valves are located in the LCS.

SURVEILLANCE FREQUENCY SR 3.6.3.1 Verify each 42 inch purge valve is sealed 31 days closed except for one purge valve in a penetration flow path while in Condition D of this LCO.

SR 3.6.3.2 Verify each 8 inch purge valve is closed 31 days except when the 8 inch purge valves are open for pressure control, ALARA or air quality considerations for personnel entry, or for Surveillances that require the valves to be open.

SR 3.6.3.3 -------------------NOTES--------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. SR 3.0.4 is not applicable Verify each containment isolation manual valve 31 days and blind flange that is located outside containment and not locked, sealed, or otherwise secured and is required to be closed during accident conditions is closed, except for containment isolation valves that are open under administrative controls.

(continued)

SAN ONOFRE--UNIT 3 3.6-13 Amendment No.

Containment Isolation Valves 3.6.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.3.4 ------------------NOTES-------------------

1. Valves and blind flanges in high radiation areas may be verified by use of administrative means.

2. SR 3.0.4 is not applicable.

Verify each containment isolation manual valve Prior to and blind flange that is located inside entering MODE 4 containment and not locked, sealed, or from MODE 5 if otherwise secured and required to be closed during accident conditions is closed, except not performed within the I

for containment isolation valves that are open previous under administrative controls. 92 days SR 3.6.3.5 Verify the isolation time of each Section A In accordance and B power operated and each automatic with the containment isolation valve is within limits. Inservice Testing Program SR 3.6.3.6 ------------------NOTES---------------------

Results shall be evaluated against acceptance criteria applicable to SR 3.6.1.1 Perform leakage rate testing for containment 184 days purge valves with resilient seals.

AND Within 92 days after opening the valve (continued)

SAN ONOFRE--UNIT 3 3.6-14 Amendment No.

PCN-552 ATTACHMENT G Associated Bases Revisions (Redline and Strikeout)

San Onofre Unit 2 Note: Bases are provided for information. Bases changes will be implemented following approval of the proposed Technical Specification change.

Containment Isolation Valves B 3.6.3 BASES (continued)

SURVEILLANCE SR 3.6.3.1 REQUIREMENTS Each 42 inch containment purge valve is required to be verified sealed closed at 31 day intervals. This Surveillance is designed to ensure that a gross breach of containment is not caused by an inadvertent or spurious opening of a containment purge valve. Detailed analysis of the purge valves failed to conclusively demonstrate their ability to close during a LOCA in time to limit offsite doses. Therefore, these valves are required to be in the sealed closed position during MODES 1, 2, 3, and 4. A containment purge valve that is sealed closed must have motive power to the valve operator removed. This can be accomplished by de-energizing the source of electric power or by removing the air supply to the valve operator. In this application, the term "sealed" has no connotation of leak tightness. The Frequency is a result of an NRC initiative, Generic Issue B-24 (Ref. 3), related to containment purge valve use during unit operations. This SR is not required to be met while in Condition D of this LCO.

This is reasonable since the penetration flow path would be isolated.

SR 3.6.3.2 This SR ensures that the minipurge valves are closed as required or, if open, open for an allowable reason. The SR is not required to be met when the purge valves are open for pressure control, ALARA or air quality considerations for personnel entry, or for Surveillances that require the valves to be open. The minipurge valves are capable ofclosing in the environment following a LOCA. Therefore, these valves are allowed to be open for limited periods of time. The 31 day Frequency is consistent with other containment isolation valve requirements discussed in SR 3.6.3.3.

SR 3.6.3.3 This SR requires verification that each containment isolation manualvalye and,.blind flance located outside containment and'not-locked, sealed, or otherwise-secured and required to be closed during accident conditions is closed.

The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the containment boundary is within design limits. This SR does not require any testing or valve manipulation. Rather, it involves verification, that those valves outside containment and capable of being mispositioned are in the correct position.

(continued)

SAN ONOFRE--UNIT 2 B 3.6-23 Amendment No. +/-29-O6q9IOO Re-+ssued-08/01/1O

Containment Isolation Valves B 3.6.3 BASES (continued)

SURVEILLANCE SR 3.6.3.3 (continued)

REQUIREMENTS Since verification of valve position for valves outside containment is relatively easy, the 31 day Frequency is based on engineering judgment and was chosen to provide added assurance of the correct positions. Valves that are open under administrative controls are not required to meet the SR during the time the valves are open. This SR does not apply to valves-that are locked, sealed, or otherwise secured in.the clo'sed position, since these were verified to be in the correc't !pos'ition'upon locking, sealing, or securing.

The first Note applies to valves and blind flanges located in high radiation areas and allows these devices to be verified closed by use of administrative means. Allowing verification by administrative means is considered acceptable, since access to these areas is typically restricted during MODES 1, 2, 3, and 4 for ALARA reasons.

Therefore, the probability of misalignment of these valves, once they have been verified to be in the proper position, is small. The second note specifies that SR 3.0.4 is not applicable.

SR 3.6.3.4 This SR requires verification that each containment isolation manual valve-and blind flanqe located inside containment and not locked, sealed, or otherwise secured and required to be closed during accident conditions is closed.

The SR helps to ensure that post accident leakage of radioactive fluids or gases outside the containment boundary is within design limits. For valves inside containment, the Frequency of "prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days" is appropriate, since these valves and flanges are operated under administrative controls and the probability of their misalignment is low.

Valves that are open under administrative controls are not reauired to meet theSR durinq the time that thev are oDen.

This SR does not'apply to-valves that are locked, sealed, or otherwise secured in the closed-position, since.these were verified to be iin'the correct position upon locking, sealing,' or-securing.

The first Note allows valves and blind flanges located in high radiation areas to be verified closed by use of administrative means. Allowing verification by (continued)

SAN ONOFRE--UNIT 2 B 3.6-24 Amendment No. 127 93/28/OO