Text

Proposed Change Number 576, Request to Revise Main Steam Safety Valve Requirements and Actions (Technical Specification 3.7.1)
	ML063170129
Person / Time
Site:	San Onofre
Issue date:	11/07/2006
From:	Katz B; Southern California Edison Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML063170129 (51)
	v • d • e

SOUTHERN CALIFORNIA Brian Katz Vice President EDISON0 An EDISON INTERNATIONAL Company November 7, 2006 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) 576 Request to Revise Main Steam Safety Valve Requirements and Actions (Technical Specification 3.7.1)

San Onofre Nuclear Generating Station Units 2 and 3 Gentlemen:

Pursuant to 10 CFR 50.90, Southern California Edison (SCE) hereby requests the following amendments to Facility Operating Licenses NPF-10 and NPF-15 for San Onofre Units 2 and 3, respectively for Technical Specification (TS) 3.7.1: change the entry condition for Action A from one or more Main Steam Safety Valves (MSSVs) inoperable to two to seven MSSVs inoperable; in Action A.1 change "less than" to "less than or equal to"; change the required completion time for Action A.2 from 12 to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months ; delete the entry for 1 inoperable MSSV per steam generator (SG) from TS Table 3.7.1-1, increase the Linear Power Level High Trip (LPLHT) setpoint specified in TS Table 3.7.1-1 for two inoperable MSSVs per SG from 86.3% of Rated Thermal Power (RTP) to 95% RTP; decrease the required LPLHT setpoint for three inoperable MSSVs per SG from 74.0% RTP to 56% RTP; decrease the required LPLHT setpoint for four inoperable MSSVs per SG from 61.6% RTP to 46% RTP; revise the Table 3.7.1-1 entries for more than 4 inoperable MSSVs per SG to combine the existing entries into a single entry; revise TS Table 3.7.1-1 to include a column for maximum allowable power; eliminate the requirement to adjust the LPLHT setpoints if the maximum allowed power is MODE 3; and reformat TS Table 3.7.1-1 and Condition B to be based on the number of inoperable MSSVs instead of the number of operable MSSVs.

Additionally, this submittal requests correction of an editorial error in the footnote for TS Table 3.7.1-2 by changing "LCO 5.5.2.10" to "Technical Specification 5.5.2.10."

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.

P.O. Box 128 San Clemente, CA 92674-0128 949-368-9275 Fax 949-368-9881

Document Control Desk November 7, 2006 SCE is making no new commitments that would result from NRC approval of the proposed amendments.

If you have any questions or require additional information, please contact Mr. A. E.

Scherer at (949) 368-7501.

Sincerely, Enclosures

1. Notarized Affidavits

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

A. Existing Technical Specification pages, Unit 2 B. Existing Technical Specification pages, Unit 3 C. Markup of Technical Specification pages, Unit 2 D. Markup of Technical Specification pages, Unit 3 E. Retyped Technical Specification pages, Unit 2 F. Retyped Technical Specification pages, Unit 3 G. Markup of Bases Changes, Unit 2 H. Markup of Updated Final Safety Analysis Report Changes, Unit 2 and Unit 3 cc: B. S. Mallett, Regional Administrator, NRC Region IV N. Kalyanam, 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, Radiological Health Branch

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

EDISON, ET AL. for a Class 103 ) Docket No. 50-361 License to Acquire, Possess, and Use a ) Amendment Application Number 247 Utilization Facility as Part of Unit No. 2 of the San Onofre Nuclear Generating Station SOUTHERN CALIFORNIA EDISON, ET AL., pursuant to 10 CFR § 50.90, hereby submit Amendment Application Number 247 to Facility Operating License NPF-10. This change is a request to revise the Technical Specification 3.7.1 requirements for inoperable main steam safety valves. In accordance with 10 CFR § 50.30(b), the following affirmation is provided: Brian Katz states that he is Vice President of Southern California Edison, is authorized to execute this oath on behalf of Southern California Edison and, to the best of his knowledge and belief, the facts set forth in this letter are true.

Respectfully submitted, Brian Katz Vice President Southern California Edison State of California County of San Diego Subscribed and sworn to (o-f ) before me, this an day of VM Vb k_-eK ,12006, by - Y'j,-" .*2L-I personally known to me @r provedt t ho basiof tisfactory eviden"e to be the person who appeared before me.

DAWN A-FARRELL Comminalon # 1623105

" Notary Public - California Notary Public SIDiego Cou&.^ I

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

EDISON, ET AL. for a Class 103 ) Docket No. 50-362 License to Acquire, Possess, and Use a ) Amendment Application Number 232 Utilization Facility as Part of Unit No. 3 )

of the San Onofre Nuclear Generating )

Station )

SOUTHERN CALIFORNIA EDISON, ET AL., pursuant to 10 CFR § 50.90, hereby submit Amendment Application Number 232 to Facility Operating License NPF-1 5. This change is a request to revise the Technical Specification 3.7.1 requirements for inoperable main steam safety valves. In accordance with 10 CFR § 50.30(b), the following affirmation is provided: Brian Katz states that he is Vice President of Southern California Edison, is authorized to execute this oath on behalf of Southern California Edison and, to the best of his knowledge and belief, the facts set forth in this letter are true.

Respectfully submitted, Brian Katz Vice President Southern California Edison State of Califomia County of San Diego Subscribed and sworn to (OF &ffjF*M) before me, this I'* day of Io ve, beJ2 12006, by --- '& _+ Z- I personally known to me Or provcd to mc on the basis oatisfactori ' evidence to be the person who appeared before me.

DWN A.FARKULJ

____________*M Cr~ 1623105 Notary Public Notar Public

\,CI San oin cou*ti

ENCLOSURE2 LICENSEE'S EVALUATION Proposed Change Number 576

SUBJECT:

Request to Revise Main Steam Safety Valve Requirements and Actions (Technical Specification 3.7.1)

1.0 INTRODUCTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements/Criteria 6.0 PRECEDENTS

7.0 ENVIRONMENTAL CONSIDERATION

8.0 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 H. Markup of Updated Final Safety Analysis Report Changes, Unit 2 and Unit 3 i

LICENSE AMENDMENT REQUEST TO REVISE MAIN STEAM SAFETY VALVE REQUIRMENTS AND ACTIONS (TS 3.7.1)

San Onofre Nuclear Generating Station, Units 2 and 3

1.0 INTRODUCTION

This request is to amend Operating Licenses NPF-10 and NPF-15 for San Onofre Nuclear Generating Station (SONGS), Units 2 and 3, respectively, to change Technical Specification (TS) 3.7.1 for the Main Steam Safety Valves (MSSVs).

The proposed change would change the entry condition for Action A from one or more Main Steam Safety Valves (MSSVs) inoperable to two to seven MSSVs inoperable; in Action A.1 change "less than" to "less than or equal to"; change the required completion time for Action A.2 from 12 to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months ; delete the entry for 1 inoperable MSSV per steam generator (SG) from TS Table 3.7.1-1, increase the Linear Power Level High Trip (LPLHT) setpoint specified in TS Table 3.7.1-1 for two inoperable MSSVs per SG from 86.3% of Rated Thermal Power (RTP) to 95% RTP; decrease the required LPLHT setpoint for three inoperable MSSVs per SG from 74.0% RTP to 56% RTP; decrease the required LPLHT setpoint for four inoperable MSSVs per SG from 61.6% RTP to 46% RTP; revise the Table 3.7.1-1 entries for more than 4 inoperable MSSVs per SG to combine the existing entries into a single entry; revise TS Table 3.7.1-1 to include a column for maximum allowable power; eliminate the requirement to adjust the LPLHT setpoints if the maximum allowed power is MODE 3; and reformat TS Table 3.7.1-1 and Condition B to be based on the number of inoperable MSSVs instead of the number of operable MSSVs.

Additionally, the proposed change would correct an editorial error in the footnote to TS Table 3.7.1-2 by changing "LCO 5.5.2.10" to "Technical Specification 5.5.2.10."

2.0 DESCRIPTION

OF PROPOSED AMENDMENT This proposed change is to revise the Technical Specifications as follows:

1. TS 3.7.1 Main Steam Safety Valves (MSSVs)

a. Revise ACTION A to read "Two to seven required MSSVs per SG inoperable."

b. Revise Required Action A.1 to read "Reduce power to less than or equal to the applicable % RTP listed in Table 3.7.1-1."

c. Revise the Completion Time for Requried Action A.2 from "12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months " to "36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months ."

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d. Reformat Table 3.7.1-1 to be based on the number of inoperable valves instead of the number of operable valves, by changing the title to "Maximum Allowable Power Level versus Inoperable MSSVs", and by changing the name of the first column to "Number of Inoperable MSSVs per Steam Generator"

e. Revise Table 3.7.1-1 to delete the entry for 8 operable valves per SG (1 inoperable MSSV per SG).

f. Revise Table 3.7.1-1 to change the required LPLHT setpoint for 7 operable valves per SG (2 inoperable MSSVs per SG) to 95% RTP.

g. Revise Table 3.7.1-1 to change the required LPLHT setpoint for 6 operable valves per SG (3 inoperable MSSVs per SG) to 56% RTP.

h. Revise Table 3.7.1-1 to change the required LPLHT setpoint for 5 operable valves per SG (4 inoperable MSSVs per SG) to 46%

RTP.

i. Revise Table 3.7.1-1 to combine the entries for more than 4 inoperable MSSVs per SG into a single entry for 5 to 7 inoperable MSSVs per SG.

j. Revise Table 3.7.1-1 to add a column for "Maximum Allowable Power", with the maximum allowable power level set at the LPLHT values for 2, 3 and 4 inoperable MSSVs per SG, and at "MODE 3" for 5 to7 inoperable MSSVs per SG.

k. For the Table 3.7.1-1 entry for "5 to 7" inoperable MSSVs per SG change the LPLHT setpoint from "MODE 3" to "Not applicable."

I. Restate the second ACTION B entry condition as "Eight or more required MSSVs per SG inoperable."

m. Revise the footnote to Table 3.7.1-2 "Main Steam Safety Valves (Lift Settings)" to change "LCO 5.5.2.10" to "Technical Specification 5.5.2.10."

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 of 13

PROPOSED TECHNICAL SPECIFICATIONS (with changes)

Unit 2: See Attachment E Unit 3: See Attachment F PROPOSED UNIT 2 TECHNICAL SPECIFICATION BASES CHANGES (Provided for information with additions highlighted and deletions struck out. Unit 3 changes will be comparable.)

See Attachment G (typical for both Units)

PROPOSED UPDATED FINAL SAFETY ANALYSIS REPORT CHANGES (Provided for information with additions highlighted and deletions struck out.)

See Attachment H (common for both Units)

3.0 BACKGROUND

This request is to change the San Onofre Units 2 and 3 Technical Specification (TS) 3.7.1 for the Main Steam Safety Valves (MSSVs). Currently, when an MSSV is inoperable, Technical Specification 3.7.1 requires the Linear Power Level High Trip (LPLHT) setpoint, and thus reactor power, to be reduced in accordance with TS Table 3.7.1-1. This is done to establish plant conditions such that the peak secondary pressure would not exceed 1210 psia (110% of the 1100 psia design pressure) in the event of an accident.

The original required LPLHT values in TS Table 3.7.1-1 were derived from an equation based on the MSSV relieving capacities. This equation did not consider the dynamic response of the plant to the transient.

In 1994, the NRC issued Information Notice (IN) 94-60 (Reference 1). IN 94-60 reported that the method used by Westinghouse to calculate the required LPLHT values may be non-conservative. IN 94-60 recommended that transient analyses be performed to validate the required LPLHT values. At SONGS, this validation was done by having the NSSS vendor (ABB Combusion Engineering) perform a transient analysis at the power level specified by TS Table 3.7.1-1 (recommendation 2 of IN 94-60 Attachment 1). This evaluation determined that the results were acceptable at the power levels listed in TS Table 3.7.1-1.

Subsequently, recent analyses have been performed which determined that with 3 and 4 inoperable MSSVs per SG, it was possible for the peak secondary pressure to significantly increase as the initial power level decreases (see Figures 1 and 2). The two primary potential reactor trips for this event are the High Pressurizer Pressure Trip (HPPT) and Low Steam Generator Level Trip (LSGLT). As the initial power level decreases, the time needed to reach the reactor trip increases. At some power level, the reactor trip becomes sufficiently delayed such that the Control Element Assembly (CEA) insertion does not occur 3 of 13

in time to mitigate the SG pressure rise.

As shown in Figure 1 for three inoperable MSSVs per SG, above approximately 68% Rated Thermal Power (RTP) the reactor trip occurs early enough that the CEA insertion mitigates the SG pressure rise. Below 68%, the reactor trip is either coincident with or after the SG pressure peak, such that the power reduction due to the reactor trip does not affect the SG peak pressure. Note that even though the acceptance criterion is not being met from 62% RTP to 68%

RTP, the acceptance criterion is met from 68% RTP to 91% RTP (the maximum allowed power level per the current Technical Specifications is 74.0% RTP for this condition, within this range). Figure 2 shows a similar trend for the case where four MSSVs per SG are inoperable.

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Figure 1 Peak SG Pressure as a Function of Power With 3 Inoperable MSSVs 1260 200 1250 N Trip Time (sec) 180 Peak SG Pressure (psia) 1240 - n ie (e 160 140 c 1230 120 1220 0 100 1210

- 80 L 1200 E

-60 iT 1190 40 1180 @ -. - - 20

~*0~O0-0 O-O~e.@ *40 1170 0 45 50 55 60 65 70 75 80 85 90 95 1(00 Power (Percent of Rated Thermal Power)

-- Peak SG Pressure (psia)

-B Acceptance Criterion (110% of Design Pressure)

- - - Trip Generated (sec)

Figure 2 Peak SG Pressure as a Function of Power With 4 Inoperable MSSVs 1300 250 1290 1280 200 1270 1260 CL 1250 150 0

1240 a) 1230 In 1220 100 1210 1200 50 1190 1180 1170 - ! 0 35 40 45 50 55 60 65 70 75 80 85 90 95 100 Power (Percent of Rated Thermal Power)

-- Peak SG Pressure (psia)

-DAcceptance Criterion (110% of Design Pressure)

- - - Trip Generated (sec) 5 of 13

As shown in Figures 3, 4, and 5, a significant pressure spike does not occur with zero, one, or two inoperable MSSVs per SG.

Figure 3 Peak SG Pressure as a Function of Power With All MSSVs Operable 1220 120 100 1210

" Trip lime (sec)

C;u 80O

. 1200 0 60 U) 1190 - . 0 -I E 40 1180 Peak SG Pressure(psia)-

20 1170 0 70 75 80 85 90 95 100 Power (Percent of Rated Thermal Power)

-- Peak SG Pressure (psia)

Acceptance Criterion (110% of Design Pressure)

- .4 - Trip Generated (sec) 6 of 13

Fi~qure 4 Peak SG Pressure as a Function of Power With 1 Inoperable MSSV per SG 1220 140 120 1210 100 Trip Time (sec) 1200 80 0

-60 E 40) 1190-Peak SG Pressure (psia) 1180- 20 1170 I0 60 65 70 75 80 85 90 95 100 Power (Percent of Rated Thermal Power)

-- Peak SG Pressure (psia)

-iAcceptance Criterion (110% of Design Pressure)

- -. - Trip Generated (sec)

Peak SG Pressure as a Function of Power With 2 Inoperable MSSVs per SG 1220 160 140 1210 e . Trip Time (sec) 4 120 "5 1200 100

0 80 4

-60 40 1180 20 1170 0 00 55 60 65 70 75 80 85 90 95 l1 Power (Percent of Rated Thermal Power)

-- Peak SG Pressure (psia)

-Acceptance Criterion (110% of Design Pressure)

- -.- - Trip Generated (sec)

Figure 5 7 of 13

Based on the detailed analyses that were performed, it is necessary to reduce the values currently specified in TS Table 3.7.1-1 for 3 and 4 inoperable MSSVs per steam generator. SONGS has established interim administrative controls to account for the non-conservative TS Table 3.7.1-1 values for 3 and 4 inoperable MSSVs per SG.

As a part of the recent analyses, it was determined that no power reduction was required for 1 inoperable MSSV per steam generator (refer to Figure 4), and that the allowable power level for 2 inoperable MSSVs per steam generator was able to be increased slightly (refer to Figure 5).

The new analyses were performed in accordance with the Nuclear Regulatory Commission (NRC) approved San Onofre Units 2 and 3 reload analysis methodology (Reference 2), and were done at the MSSV lift settings specified in Technical Specification Table 3.7.1-2 using an as-found lift setting of +2% above the table value, as stated in the footnote to Table 3.7.1-2.

The proposed changes are also consistent with the general recommendations of Technical Specification Task Force Traveler 235 (TSTF-235) Rev. 1, "MSSV Changes" (Reference 3). This request addresses the TSTF-235 issues listed as being associated with the Westinghouse Standard Technical Specifications (STS), as the Combustion Engineering Standard Technical Specification (STS) wording was not updated for IN 94-60.

The completion time for TS 3.7.1 Required Action A.2 is being increased from 12 to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This change is consistent with TSTF-235 (Reference 3) and NUREG-1432 (Reference 4).

TS Table 3.7.1-1 is being reformated to be more consistent with NUREG-1432 (Reference 4), and to be expressed in terms of inoperable MSSVs rather than operable MSSVs.

4.0 TECHNICAL ANALYSIS

TS 3.7.1 ACTION A The limiting analysis for inoperable MSSVs is the Loss of Condenser Vacuum with a Single Failure (LOCV+SF). This event is described in Sections 15.2.2.3 and 15.10.2.2.3 of the Updated Final Safety Analysis Report (UFSAR). The acceptance criteria of concern for this event are that the peak secondary system pressure does not exceed 110% of the design pressure of 1100 psia (i.e., 1210 psia).

Analyses have been perfornmed which demonstrate that acceptable results are obtained from rated power (plus uncertainty) with one MSSV inoperable per SG. The analyses were performed in accordance with the NRC approved methodology (Reference 2), which is specified in Technical Specification 5.7.1.5. As there is no need to reduce power for one inoperable MSSV per SG, this action statement is being 8 of 13

revised to only require entry if two to seven MSSVs per SG are inoperable. This is consistent with Table 3.7.1-1 and the second entry condition for ACTION B.

TS 3.7.1 Required Action A.1 Currently, this requires power to be reduced to below the value specified in Table 3.7.1-1. As discussed later, the table is being reformatted to add a column for "Maximum Allowable Power', so this entry is revised to say "Reduce power to less than or equal to the applicable %RTP listed in Table 3.7.1-1 ."

TS 3.7.1 Required Action A.2 Completion Time The completion time for this required action is increased from 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , consistent with the NRC approved Technical Specification Task Force (TSTF) traveler TSTF-235 Rev. 1 (Reference 3) and with the NUREG-1432 Standard Technical Specifications for Combustion Engineering Plants (Reference 4).

Note that lowering the LPLHT trip setpoint is a backup to the operator actions required per Required Action A.1. With operators continually monitoring reactor power, there is no technical need to lower the LPLHT setpoint, as protection for an event is provided by the HPPT in conjunction with the initial power level set and monitored by the operators.

Therefore, 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is a reasonable time based on the time required to perform the power reduction, reset the setpoints on all channels of the reactor protection system, and on the low probability of three concurrent events occurring (the power must rise above the power established per Required Action A.1, the operators do not mitigate the power increase, and a transient that results in steam generator pressurization must occur).

TS Table 3.7.1-1 The first change to Table 3.7.1-1 is to change the format of the table to be based on the number of inoperable MSSVs per SG, rather than the number of operable MSSVs per SG. This is being done as a human factors improvement, as the entry condition for the ACTION statement is based on inoperable MSSVs. This is an editorial change.

The technical changes to Table 3.7.1-1 are as follows:

The table is being reformatted to add a column for "Maximum Allowable Power

(%RTP) consistent with NUREG-1432 (Reference 4).

The Table is being renamed to "Maximum Allowable Power Level versus Inoperable MSSVs", as the primary purpose of the table is to provide the operators with the maximum allowable power with inoperable MSSVs.

The first entry (for 8 operable valves, or 1 inoperable valve), is being deleted.

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This is consistent with the preceding change to TS 3.7.1 ACTION A, which is now allowing operation with 1 inoperable MSSV per SG.

The MAXIMUM ALLOWABLE LINEAR POWER LEVEL HIGH TRIP setpoint for 2 inoperable MSSVs per SG (7 operable MSSVs per SG) is increased from 86.3%

RTP to 95% RTP. This is is the maximum acceptable power level as determined by the limiting LOCV+SF analysis described in the preceding section on the change to TS 3.7.1 ACTION A. The MAXIMUM ALLOWABLE POWER for this condition will be set to 95% (note that trip and power measurement uncertainties were accounted for in setting the LPLHT setpoint, and margin to the trip will be maintained by the operating procedures).

The MAXIMUM ALLOWABLE LINEAR POWER LEVEL HIGH TRIP setpoint for 3 inoperable MSSVs per SG (6 operable MSSVs per SG) is decreased from 74.0%

RTP to 56% RTP. This is is the maximum acceptable power level as determined by the limiting LOCV+SF analysis described in the preceding paragraph on the change to TS 3.7.1 ACTION A. The MAXIMUM ALLOWABLE POWER for this condition will be set to 56%.

The MAXIMUM ALLOWABLE LINEAR POWER LEVEL HIGH TRIP setpoint for 4 inoperable MSSVs per SG (5 operable MSSVs per SG) is decreased from 61.6%

RTP to 46% RTP. This is is the maximum acceptable power level as determined by the limiting LOCV+SF analysis described in the preceding paragraph on the change to TS 3.7.1 ACTION A. The MAXIMUM ALLOWABLE POWER for this condition will be set to 46%.

The Table 3.7.1-1 entries for more than 4 inoperable MSSVs per SG are combined into a single entry. The MAXIMUM ALLOWABLE POWER for this condition will be "MODE 3", and the LPLHT setpoint will be "Not applicable" (as per Table 3.3.1-1 the LPLHT function is not required in MODE 3).

TS 3.7.1 ACTION B An editorial change is being made to to the second entry condition for ACTION B to state the action in terms of inoperable MSSVs. The revised wording is "Eight or more required MSSVs per SG inoperable" This is done as a human factors improvement to make this wording consistent with the wording used in Action A (i.e., based on the number of inoperable MSSVs per SG).

TS Table 3.7.1-2 The change to Table 3.7.1-2 is to change "LCO 5.5.2.10" to "Technical Specification 5.5.2.10." This is being done because the administrative controls in section 5 of the Technical Specifications are not Limiting Conditions for Operation (LCO). This is an editorial change.

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5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration Southern California Edison (SCE) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

Based on a detailed plant transient analysis, the Limiting Conditions for Operation (LCOs) and Action statements will continue to restrict operation to within the regions that provide acceptable results. The safety analysis was performed in accordance with the Nuclear Regulatory Commission (NRC) approved San Onofre Units 2 and 3 reload analysis methodology, and considered the concerns identified in NRC Information Notice 94-60.

The increase in Completion Time for Required Action 3.7.1.A.2 from 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is consistent with NUREG-1432 Revision 3, "Standard Technical Specifications for Combustion Engineering Plants."

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not add any new equipment, modify any interfaces with any existing equipment, alter the equipment's function, or change the method of operating the equipment. The proposed change does not alter plant conditions in a manner that could affect other plant components. The proposed change does not cause any existing equipment to become an accident initiator.

The increase in Completion Time for Required Action 3.7.1.A.2 from 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is consistent with NUREG-1432 Revision 3, "Standard Technical Specifications for Combustion Engineering Plants."

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The Limiting Conditions for Operation (LCOs) and Action statements will continue to restrict operation such that the American Society of Mechanical Engineers (ASME) code requirements continue to be met. The analyses were performed using the NRC approved San Onofre Units 2 and 3 reload analysis methodology. Therefore, the proposed change will have no impact on the margins as defined in the Technical Specification bases.

The increase in Completion Time for Required Action 3.7.1.A.2 from 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is consistent with NUREG-1432 Revision 3, "Standard Technical Specifications for Combustion Engineering Plants."

Therefore, this change does not involve a significant reduction in a margin of safety.

Based on the above, SCE concludes that the proposed amendment presents 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.

5.2 Applicable Regulatory Requirements/Criteria The proposed changes are consistent with NRC Information Notice (IN) 94-60, "Potential Overpressurization of Main Steam System," in that a detailed plant transient response analysis was performed (recommendation 2 of IN 94-60 Attachment 1). This analysis included a parametric evaluation to determine the allowable power levels as a function of inoperable Main Steam Safety Valves (MSSVs). The minimum power levels considered in the analysis were based on the enthalpy based equation provided in IN 94-60. The method used is more conservative than that specified in NUREG 1432, Revision 3, "Standard Technical Specifications for Combustion Engineering Plants."

6.0 PRECEDENTS

1. The proposed format for Table 3.7.1-1 (listing the number of inoperable MSSVs instead of the number of operable MSSVs) and use of analytically determined values for Table 3.7.1-1 instead of the current linear power reduction relationship is consistent with the MSSV portions of Technical Specification Amendment 222 for Arkansas Nuclear One, Unit No. 2 (Facility Operating License No. NPF-6).

2. This Technical Specification Change is consistent with the approach given in Information Notice 94-60, in that the analyses for this submittal were 12 of 13

performed using a detailed specific analysis (IN 94-60 Attachment 1 recommendation 2), and the analyses were done to a sufficiently low power to ensure that the peak secondary pressure acceptance criteria will be met under all conditions.

3. Technical Specification Task Force Traveler 235, Rev. 1, MSSV Changes." (Reference 3)

4. NUREG-1432, Revision 3, "Standard Technical Specifications for Combustion Engineering Plants." (Reference 4)

7.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendments would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendments do not involve (i)a significant hazards consideration, (ii)a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendments meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environment impact statement or environmental assessment need be prepared in connection with these proposed amendments.

8.0 REFERENCES

1. Information Notice 94-60, "Potential Overpressurization of Main Steam System."

2. SCE-9801-P-A, "Reload Analysis Methodology for the San Onofre Nuclear Generating Station Units 2 and 3," June 1999.

3. Technical Specification Task Force Traveler 235, Rev. 1, "MSSV Changes."

4. NUREG-1432, Revision 3, "Standard Technical Specifications for Combustion Engineering Plants."

13 of 13

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration Southern California Edison (SCE) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

Based on a detailed plant transient analysis, the Limiting Conditions for Operation (LCOs) and Action statements will continue to restrict operation to within the regions that provide acceptable results. The safety analysis was performed in accordance with the Nuclear Regulatory Commission (NRC) approved San Onofre Units 2 and 3 reload analysis methodology, and considered the concerns identified in NRC Information Notice 94-60.

The increase in Completion Time for Required Action 3.7.1.A.2 from 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is consistent with NUREG-1432 Revision 3, "Standard Technical Specifications for Combustion Engineering Plants."

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change does not add any new equipment, modify any interfaces with any existing equipment, alter the equipment's function, or change the method of operating the equipment. The proposed change does not alter plant conditions in a manner that could affect other plant components. The proposed change does not cause any existing equipment to become an accident initiator.

The increase in Completion Time for Required Action 3.7.1.A.2 from 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is consistent with NUREG-1432 Revision 3, "Standard Technical Specifications for Combustion Engineering Plants."

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

11 of 13

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The Limiting Conditions for Operation (LCOs) and Action statements will continue to restrict operation such that the American Society of Mechanical Engineers (ASME) code requirements continue to be met. The analyses were performed using the NRC approved San Onofre Units 2 and 3 reload analysis methodology. Therefore, the proposed change will have no impact on the margins as defined in the Technical Specification bases.

The increase in Completion Time for Required Action 3.7.1.A.2 from 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months is consistent with NUREG-1432 Revision 3, "Standard Technical Specifications for Combustion Engineering Plants."

Therefore, this change does not involve a significant reduction in a margin of safety.

Based on the above, SCE concludes that the proposed amendment presents 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.

5.2 Applicable Regulatory Requirements/Criteria The proposed changes are consistent with NRC Information Notice (IN) 94-60, "Potential Overpressurization of Main Steam System," in that a detailed plant transient response analysis was performed (recommendation 2 of IN 94-60 Attachment 1). This analysis included a parametric evaluation to determine the allowable power levels as a function of inoperable Main Steam Safety Valves (MSSVs). The minimum power levels considered in the analysis were based on the enthalpy based equation provided in IN 94-60. The method used is more conservative than that specified in NUREG 1432, Revision 3, "Standard Technical Specifications for Combustion Engineering Plants."

6.0 PRECEDENTS

1. The proposed format for Table 3.7.1-1 (listing the number of inoperable MSSVs instead of the number of operable MSSVs) and use of analytically determined values for Table 3.7.1-1 instead of the current linear power reduction relationship is consistent with the MSSV portions of Technical Specification Amendment 222 for Arkansas Nuclear One, Unit No. 2 (Facility Operating License No. NPF-6).

2. This Technical Specification Change is consistent with the approach given in Information Notice 94-60, in that the analyses for this submittal were 12 of 13

performed using a detailed specific analysis (IN 94-60 Attachment 1 recommendation 2), and the analyses were done to a sufficiently low power to ensure that the peak secondary pressure acceptance criteria will be met under all conditions.

3. Technical Specification Task Force Traveler 235, Rev. 1, MSSV Changes." (Reference 3)

4. NUREG-1432, Revision 3, "Standard Technical Specifications for Combustion Engineering Plants." (Reference 4)

7.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendments would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendments do not involve (i) a significant hazards consideration, (ii)a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendments meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environment impact statement or environmental assessment need be prepared in connection with these proposed amendments.

8.0 REFERENCES

1. Information Notice 94-60, "Potential Overpressurization of Main Steam System."

2. SCE-9801-P-A, "Reload Analysis Methodology for the San Onofre Nuclear Generating Station Units 2 and 3," June 1999.

3. Technical Specification Task Force Traveler 235, Rev. 1, "MSSV Changes."

4. NUREG-1432, Revision 3, "Standard Technical Specifications for Combustion Engineering Plants."

13 of 13

PCN-576 Attachment A EXISTING TECHNICAL SPECIFICATIONS UNIT 2

MSSVs 3.7.1 3.7 PLANT SYSTEMS 3.7.1 Main Steam Safety Valves (MSSVs)

LCO 3.7.1 The MSSVs shall be OPERABLE as specified in Table 3.7.1-1 and Table 3.7.1-2.

APPLICABILITY: ;MODES 1, 2, and 3.

ACTIONS

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

Separate Condition entry is allowed for each MSSV.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Reduce power to less 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months MSSV per SG than the applicable inoperable. % RTP listed in Table 3.7.1-1.

AND A.2 Reduce the Linear 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Power Level High trip setpoint in accordance with Table 3.7.1-1.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND OR B.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months One or more Steam Generators with less than two MSSVs OPERABLE per SG.

SAN ONOFRE--UNIT 2 3.7-1 Amendment No. 127

MSSVs 3.7.1 Table 3.7.1-i *(page I of 1)

Maximum Allowable Linear Power Level-High Trip Setpoints versus OPERABLE MSSVs

MAXIMUM ALLOWABLE MINIMUM NUMBER :OF :LINEAR POWER LEVEL MSSVs PER STEAM GENERATOR :HIGH TRIP REQUIRED OPERABLE (% RTP) 8 98.6 7 86.3

6 74.0

5 61.6 4 MODE 3 3 MODE 3 2 MODE 3 SAN ONOFRE--UNIT 2 3.7-3 Amendment No. 127

MSSVs 3.7.1 Table 3.7.1-2 (page 1 of 1)

Main Steam Safety Valves (Lift Settings)

VALVE NUMBER LIFT SETTING*

Steam Generator Steam Generator (psig)

1 #2 2PSV-8401 2PSV-8410 1085 2PSV-8402 2PSV-8411 1092 2PSV-8403 2PSV-8412 1099 2PSV-8404 2PSV-8413 1106 2PSV-8405 2PSV-8414 1113 2PSV-8406 2PSV-8415 1120 2PSV-8407 2PSV-8416 1127 2PSV-8408 2PSV-8417 1134 2PSV-8409 2PSV-8418 1140 The lift setting pressure shall correspond to ambient conditions of the valve at nominal operating temperature and pressure. Each MSSV has an as-found tolerance of +2%/-3%. Following testing according to LCO 5.5.2.10, MSSVs will be set within +/-l% of the specified lift setpoint.

SAN ONOFRE.-UNIT 2 3.7-4 Amendment No. 7,163 I

PCN-576 Attachment B EXISTING TECHNICAL SPECIFICATIONS UNIT 3

!MSSVs 3.7.1 3.7 PLANT SYSTEMS 3.7.1 Main Steam Safety Valves (MSSVs)

LCO 3.7.1 The MSSVs shall be OPEIRABLE~as specified in Table 3.7.1-1 and Table 3.7.1-2.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

.-------------- NOTE------------------------------

Separate :Condition entry is allowed for each MSSV.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Reduce power to less 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months MSSV per SG than the applicable inoperable. % RTP listed in Table 3.7.1-1.

AND A.2 Reduce the Linear 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Power Level High trip setpoint in accordance with Table.

3.7.1-1.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND

-OR B.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months One or more Steam Generators with less than two MSSVs OPERABLE per SG.

SAN ONOFRE--UNIT 3 3.7-1 Amendment'No. 116

,MSSVs 3.7.1 Table 3.7.1-1 :(page 1 of 1) fMaximum Allowable Linear Power Level-High Trip Setpoints versus OPERABLE MSSVs MAXIMUM ALLOWABLE

iMINIMUM NUMBER OF LINEAR POWER LEVEL

,MSSVs P:ER,.STEAMGENERATOR HIGH TRIP REQUIRED OPERABLE (% RTP) 8 98.6 7 86.3 6 74.0

,5 61.6 4 ýMODE 3 3 MODE 3 2 MODE 3 SAN ONOFRE--UNIT 3 3.7-3 Amendment No. 116

MSSVs 3.7.1 Table 3.7.1-2 '(page I of 1)

Main Steam -Safety Valves '(Lift Settings)

VALVE NUMBER LIFT SETTING*

Steam Generator Steam Generator (psig)

'#1 #2

. ........ ; " 3.

. ' 2-., . . ..

3PSV-8401 3PSV-8410 1085 3PSV-8402 3PSV-8411 1092

.3PSV-8403 3PS;V-8412

-,* 1099 3PSV-8404 3PSV-8413 1106 3PSV-8405 3PSV-8414 1113 3PSV-8406 3PSV-8415 1120 3PSV-8407 ' 3PSV-8416 1121 3PSV-8408 3PSV-8417 ,1134 3PSV-8409 3PSV-8418 1140 The lift setting pressure shall correspond to ambient conditions of the valve at nominal operating temperature and pressure. Each MSSV has an as-found tolerance of +2%/-3%. Following testing according to LCO 5.5.2.10, MSSVs will be set within +/-1%of the specified lift setpoint.

SAN ONOFRE--UNIT 3 3.7-4 Amendment No. +-+6,154 I

PCN-576 Attachment C PROPOSED TECHNICAL SPECIFICATIONS UNIT 2 (Additions highlighted and deletions struck out)

MSSVs 3.7.1 3.7 PLANT SYSTEMS 3.7.1 Main Steam Safety Valves (MSSVs)

LCO 3.7.1 The MSSVs shall be OPERABLE as specified in Table 3.7.1-1 and Table 3.7.1-2.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

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

Separate Condition entry is allowed for each MSSV.

CONDITION REQUIRED ACTION COMPLETION TIME

,wotoseven 9me-e

~A

-. A.1 Reducpenowrtn, less 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months terequi red MSSVsi. than the per SG ino perabl e. appl i~c-a'b -iRTP listed in Table 3.7.1-1.

AND A.2 Reduce the Linear +1-hours tPower Level High trip setpoint in accordance with Table 3.7.1-1.

B. Required Action and B.1 ;Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND DOR B.2 Be in :MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Fiotht. or monr.e -req-uivred i no pra~bl e.

One or fmore Steam Generators with less than two mssvs 9PERAL ,¥¥*.E per3 S..3¥ SAN ONOFRE-UNIT 2 3.7-1 Amendment No. +29-

MSSVs 3.7.1 Table 3.7.1-1 (page 1 of 1)

Maximum Allowable Li near ..Pnwpr I Pvel High Tri p Setpi -ts versus In*oper.able MSSVs

'*# :*i**i~i*i*:~i'*ALLOWABLE MAXIMUM LINEAR MINIMUM NUMBER OF 4*.PE`RA1BLE M0MIM ALLOWABLEVELIHNIE MSSVs PER STEAM GENERATOR- ALWh POE POWER LEVEL HIGH REQUIREB ERABLE %RTP) --RTRP 5 { ý7~4 :MOD4E ~3 Not qap]pica~bl e M*ODE 3 SAN ONOFRE-UNIT 2 3.7-3 Amendment No. +2-T

MSSVs 3.7.1 Table 3.7.1-2 (page I of 1)

Main Steam Safety Valves (Lift Settings)

VALVE NUMBER LIFT SETTING*

Steam Generator Steam Generator (psig)

1 #2 2PSV-8401 2PSV-8410 1085 2PSV-8402 2PSV-8411 1092 2PSV-8403 2PSV-8412 1099 2PSV-8404 2PSV-8413 1106 2PSV-8405 2PSV-8414 1113 2PSV-8406 2PSV-8415 1120 2PSV-8407 2PSV-8416 1127 2PSV-8408 2PSV-8417 1134 2PSV-8409 2PSV-8418 1140 The lift setting pressure shall correspond to ambient conditions of the valve at nominal operating temperature and pressure. Each MSSV haq An aq-fniind tnlprance of +2%/-3%. Following testing according to Techni'ca'l

Sp.ecificaition +--5.5.2.10, MSSVs will be set within +/-1%of the specified lift setpoint.

SAN ONOFRE--UNIT 2 3.7-4 Amendment No. 127,163

PCN-576 Attachment D PROPOSED TECHNICAL SPECIFICATIONS UNIT 3 (Additions highlighted and deletions struck out)

MSS3V s 13.7.1 3.7 PLANT SY.STEMS 3.7.1 Main Steam Safety Valves (MSSVs)

LCO 3.7.1 .The'MSSVs shall be OPERABLE as specified in Table 3.7.1-1 and Table 3.7.1-2.

APPLICABI:LI TY: :MODES .1,2, and 3.

ACTIONS

. ----------------------- NOTE-------------------------------------

Separate Condition entry is allowed for each MSSV.

CONDITION REQUIRED 'ACTION COMPLETION TIME A. sSwbet6s#ft.-h A.1 Reduc. p rtn. less 4 *hours

-requred 'MSSV,- than &requail to the per SG inoperabl e. appl i cab-]e % RTP listed in Table

3.7.1-i..

AND A.2 'Reduce the Linear 6 2-hours

.P-oweer

. .:Lev.el 'High trt~p setpoint in accordance with Table 3.7.1-1.

B. Required Action and B.1 Be in MODE 3. 6 *hours associated Completion Time not met. AND OR B.2 *Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months n re .F..ht required MSSAI' npr &%

Orc ar more Steam Genrartors with less1 than two MSSY5 SAN ONOFRE--UNIT 3 3.7-1 Amendment No. 44-6

MSSVs 3.7.1 Table 3.7.1-1 (page 1 of 1)

Maximum Allowable Lnear Pnwpr Ipvel-',igh Trip dtc: L U11 Di versus IhQ.peratbe MSSVs MAXIMUM ALLOWABLE LINEAR MIN-IMUM NUMBER OF I.'NOPE.RABLE BEMM MACY MSSVs PER STEAM GENERATOR ER A-LLOWA*Lf:QPE*. POWER LEV.EL HIGH

" * "* * ...... ~(TRIP * **:*(%o REQUIREB-P- RABL-E RTP)

.4~

,to 74

-5 MOE3 56 Not'a!P;Pl icb4 5M67-4---G M1ODE 3 SAN ONOFRE--UNIT 3 3.7-3 Amendment No. +-ý&

MSSVs 3.7.1 Table 3.7.1-2 (page I of 1)

Main Steam Safety Valves (Lift Settings)

VALVE NUMBER LIFT SETTING*

Steam Generator Steam Generator (psig)

1 #2 3PSV-8401 3PSV-8410 1085 3PSV-8402 3PSV-8411 1092 3PSV-8403 3PSV-8412 1099 3PSV-8404 3PSV-8413 1106 3PSV-8405 3PSV-8414 1113 3PSV-8406 3PSV-8415 1120 3PSV-8407 3PSV-8416 1127 3PSV-8408 3PSV-8417 1134 3PSV-8409 3PSV-8418 1140

The lift setting pressure shall correspond to ambient conditions of the valve at nominal operating temperature and pressure. Each MSSV.hAs, a*n.

as-fmind, tolnprance of +2%/-3%. Following testing according to Teohýi kd Se-fcio'*ction 4ý--5.5.2.10, MSSVs will 'be set within +/-l% of te. .

specified lift setpoint.

SAN ONOFRE--UNIT 3 3.7-4 Amendment No. 16,1-54

PCN-576 Attachment E PROPOSED TECHNICAL SPECIFICATIONS UNIT 2 (with changes)

MSSVs 3.7.1 3.7 PLANT SYSTEMS 3.7.1 Main Steam Safety Valves (MSSVs)

LCO 3.7.1 The MSSVs shall be OPERABLE as specified in Table 3.7.1-1 and Table 3.7.1-2.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

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

Separate Condition entry is allowed for each MSSV.

CONDITION REQUIRED ACTION COMPLETION TIME A. Two to seven required A.1 Reduce power to less 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months MSSVs per SG than or equal to the inoperable, applicable % RTP listed in Table 3.7.1-1.

AND A.2 Reduce the Linear 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Power Level High trip setpoint in accordance with Table 3.7.1-1.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND OR B.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Eight or more required MSSVs per SG inoperable.

SAN ONOFRE--UNIT 2 3.7-1 Amendment No.

MSSVs 3.7.1 Table 3.7.1-1 (page 1 of 1)

Maximum Allowable Power Level versus Inoperable MSSVs MAXIMUM LMAXIMUM ALLOWABLE NUMBER OF INOPERABLE ALLOWABLE POWER LINEAR POWER MSSVs PER STEAM GENERATOR (% RTP) LEVEL HIGH TRIP

(% RTP) 2 95 95 3 56 56 4 46 46 5 to 7 MODE 3 Not applicable SAN ONOFRE--UNIT 2 3.7-3 Amendment No.

MSSVs 3.7.1 Table 3.7.1-2 (page I of 1)

Main Steam Safety Valves (Lift Settings)

VALVE NUMBER LIFT SETTING*

Steam Generator Steam Generator (psig)

1 #2 2PSV-8401 2PSV-8410 1085 2PSV-8402 2PSV-8411 1092 2PSV-8403 2PSV-8412 1099 2PSV-8404 2PSV-8413 1106 2PSV-8405 2PSV-8414 1113 2PSV-8406 2PSV-8415 1120 2PSV-8407 2PSV-8416 1127 2PSV-8408 2PSV-8417 1134 2PSV-8409 2PSV-8418 1140 The lift setting pressure shall correspond toambient conditions of the valve at nominal operating temperature and pressure. Each MSSV has an as-found tolerance of +2%/-3%. Following testing according to Technical Specification 5.5.2.10, MSSVs will be set within +/-1% of the specified lift setpoint.

SAN ONOFRE--UNIT 2 3.7-4 Amendment No.

PCN-576 Attachment F PROPOSED TECHNICAL SPECIFICATIONS UNIT 3 (with changes)

MSSVs 3.7.1 3.7 PLANT SYSTEMS 3.7.1 Main Steam Safety Valves (MSSVs)

LCO 3.7.1 The MSSVs shall be OPERABLE as specified in Table 3.7.1-1 and Table 3.7.1-2.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

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

Separate Condition entry is allowed for each MSSV.

CONDITION REQUIRED ACTION COMPLETION TIME A. Two to seven required A.1 Reduce power to less 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months MSSVs per SG than or equal to the inoperable, applicable % RTP listed in Table 3.7.1-1.

AND A.2 Reduce the Linear 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Power Level High trip setpoint in accordance with Table 3.7.1-1.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND OR B.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Eight or more required MSSVs per SG inoperable.

SAN ONOFRE--UNIT 3 3.7-1 Amendment No.

MSSVs 3.7.1 Table 3.7.1-1 (page 1 of 1)

Maximum Allowable Power Level versus Inoperable MSSVs MAXIMUM LMAXIMUM ALLOWABLE NUMBER OF INOPERABLE ALLOWABLE POWER LINEAR POWER MSSVs PER STEAM GENERATOR RTP) LEVEL HIGH TRIP

(% RTP) 2 95 95 3 56 56 4 46 46 5 to 7 MODE 3 Not applicable SAN ONOFRE--UNIT 3 3.7-3 Amendment No.

MSSVs 3.7.1 Table 3.7.1-2 (page 1 of 1)

Main Steam Safety Valves (Lift Settings)

VALVE NUMBER LIFT SETTING*

Steam Generator Steam Generator (psig)

1 #2 3PSV-8401 3PSV-8410 1085 3PSV-8402 3PSV-8411 1092 3PSV-8403 3PSV-8412 1099 3PSV-8404 3PSV-8413 1106 3PSV-8405 3PSV-8414 1113 3PSV-8406 3PSV-8415 1120 3PSV-8407 3PSV-8416 1127 3PSV-8408 3PSV-8417 1134 3PSV-8409 3PSV-8418 1140 The lift setting pressure shall correspond to ambient conditions of the valve at nominal operating temperature and pressure. Each MSSV has an as-found tolerance of +2%/-3%. Following testing according to Technical Specification 5.5.2.10, MSSVs will be set within +/-1% of the specified lift setpoint.

SAN ONOFRE--UNIT 3 3.7-4 Amendment No.

PCN-576 Attachment G Markup of Bases Changes, Unit 2 (Provided for information with additions highlighted and deletions struck out)

MSSVs B 3.7.1 B 3.7 PLANT SYSTEMS B 3.7.1 Main Steam Safety Valves (MSSVs)

BASES BACKGROUND The primary purpose of the MSSVs is to provide overpressure protection for the secondary system. The MSSVs also provide

protection against overpressurizing the reactor coolant pressure boundary by providing a heat sink for the removal of energy from the Reactor Coolant System (RCS) if the preferred heat sink, provided by the Condenser and Circulating Water System, is not available.

Nine MSSVs are located on each main steam header, outside containment, upstream of the main steam isolation valves,--as described inm the UFSAR, Section 5.2 (Ref. 1). The tiSSys' rated capa*c*y passes the full steam flow at 102% of 3390

-MWt (1,00%ý 2%ý for instrumen~t error of the original RATFED THIERMlAL POWER .[RTP] of 3390 ýMWt. Increased instrument-..

accuraey has allowed an increase to the Lieensed RT P '-;: theL cur h~e nt0 f343 Ilt) iththcvalves full' n A dies nfR, rn IiFS'ARli . Ž , th SV-sem*.sv

ý,pr sir Thi s meets the p~s~N requirements of Section III ýof the ASME Code (Ref. 2).

ThIe ASME requirement that MSSVs lift settings should be within 1%*of the specified setpoint reflects two *separate objectives: *the objective to maintain lift setpoints within the bounds of the Safety Analysis and an objective to minimize t~he number of valves which operate to mitigate an event 'by staggering the valve setpoints.

This second requirement to stagger setpoints reflects good engineering design, but not safety requirements. The objective to stagger valve setpoints constrains the less restrictive Safety Analysis requirement as a condition of Operability.

The radiological release assumptions used in the Steam Generator Tube Rupture dose assessment bound the source terms which are based on a low MSSV setpoint of 1100 psia with 15% MSSV blowdown, and considering the appropriate setpoint tolerance.

(conti nued)

SAN ONOFRE--UNIT 2 B 3.7-1 Amendment No. 127- -3Jý-0+

MSSVs B 3.7.1 BASES (continued)

LCO This LCO requires all MSSVs to be OPERABLE in compliance with Reference 2, even though this is not a requirement of the DBA analysis. This is because operation with moi- 4-1-s-than nxiez

n' _am a the full number

.F-MSSVs requires limitations on allowable THERMAL POWER (to meet Reference 2 requirements) and adjustment to Reactor Protection System trip setpoints. These limitations are according to those shown in Table 3.7.1-1, Required Action A.1, and Required Action A.2. An MSSV is considered inoperable if it fails to open upon demand.

The OPERABILITY of the MSSVs is defined as the ability to open in accordance with Lift Settings specified in Table 3.7.1-2, relieve Steam Generator overpressure, and reseat when pressure has been reduced. The OPERABILITY of the MSSVs is determined by periodic surveillance testing in accordance with the inservice testing program.

The Lift Settings specified in Table 3.7.1-2 correspond to ambient conditions of the valve at nominal operating temperature and pressure.

This LCO provides assurance that the MSSVs will perform their designed safety function to mitigate the consequences of accidents that could result in a challenge to the Reactor Coolant :Pressure Boundary.

APPLICABILITY In MODE 1, the accident analysis requires a minimum of five

MSSVs per Steam Generator which is limiting and bounds all lower MODES. In MODES 2 and 3, both the ASME Code and the accident analysis require only one MSSV per Steam Generator to provide overpressure protection.

In MODES 4 and 5, there are no credible transients requiring the MSSVs.

The Steam Generators are not normally used for heat removal in MODES 5 and 6, and thus cannot be overpressurized; there is no requirement for the MSSVs to be OPERABLE in these MODES.

(continued)

SAN ONOFRE--UNIT 2 B 3.7-3 Amendment No.- +/-2-7--/G18/98

MSSVs B 3.7.1 BASES (continued)

ACTIONS The ACTIONS table is modified by a Note indicating that separate Condition entry is allowed for each MSSV.

A.1 With -tw*o sev*en one or more MSSVs Pe0r 'si*e'arp *g~enera~to

,to G(S.)

inoperable reduuce power so that the available MSSV relieving capacity meets Reference 2 requirements for the applicable THERMAL POWER. Operation with less than all nine MSSVs OPERABLE for each Steam Generator is permissible, if THERMAL POWER is proportiona.y limited to the relief capacity of the remaining MSSVs. This is accomplished by'restricting THERMAL POWER so that the energy transfer to the most limiting Steam Generator is not greater than the available relief capacity in that Steam Generator.

Operation at or below the allowable power will ensure the design overpressure limits will not be exceeded.

t-yUoRf1a'n.

Tb~~w ýpobbi c~iqA~~ Ve-ýt*~

js,-p,,sd

~

ti woul t-Jejar&

reqy resateato, oftiMSS A.2 With tw.w o to '{f*or one. o fmar rlSSVs 0perSG inoperable, the ceiling on the Lj-hear Power .Level -High trip setpoint is reduced. The reduced reactor trip allowable values are lbaIed r.-ed.daiS ana...lys.'is .bf. ÷tihe wi~th a Conic~urrent Sivncpe Fail],ure eve~nt (Ref. ý3_ 'This

'i , ^ - - " ,-4 l ... Y - . . . . . . -- !k d.6n a d t' - +/-UUMu- Loss frjnde se 'Vj/\/

Aio'n -A.rhY t LeVi, Ip.H igh

.t.rip. is not reyr~'~ dri-d onthe following bases.

where.'

S~P redueed reaetor trip allowable value in pereent 4 REATEDr TH4E WR*AIP0lrP V numr

,aximum f, .,,,uperablc safety valves per 111.0 -ower Levl ihp*,e valu,e from, Table 3.3.1 1, 0RatrPoetv ytm X -ntoMt, atoty l. .. of all safety valves per X.rel* total i steam line inI1I, ,

(continued)

SAN ONOFRE--UNIT 2 B 3.7-4 Amendment No. 4-24

MSSVs B 3.7.1 BASES (continued)

ACTIONS A.2 (continued)

Y maximum relieving capacity of any anc safety valve The operator should limit the maximum steady state power level to some value slight* Ibelow y this setpoint to avoid an inadvertent overpower trip. The ampletian , Time of 12 haurs for Rnquired Action A.2 is based an operating exp resetting all ehannclsaf a prate*tive fniAn and on the low probability of the accurrcnce of a transient that cauld result in steam generator overpressure during this period.

The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time far Required A.tin* A.1 is cansistent with existing operating experince.

Tasheoi: ' etion Timeof r, neormrer`+ui 6f t iso n erj based at o h~av e ] re ulrteo o prf.*~ormeii B;t~e,*powerS

t res-s--t-F6t-w

,,crs r 6,,f pe G ~t'he uit must ber pltce in t'a MOEi reasonabl pe,rbasedc-,'-,

on op6ertingto eine ec h associated icompltionTim h f oner mondiSteams an wifhthe LCOS~ cansnotbepretore to OEaBieveti statusi the orderlymann per Snd witheounit musthbelplacedniinn uai whic the LCO dosnot Pe rABILTo Oa EvthsE statusin the unit must 'be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the assoifiateCoption MSTimefrom ift rc spoints full poweror m oredtancm in wt conditions an required unit conditions orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.1.1 REQUI REMENTS Thi~s SR verifies the OPERABILITY of the MSSVs by the verification of each MSSV lift setpoints in accordance with the inservice testing program. The ASME Code,Section XI (Ref. 4), requires that safety and relief valve tests be performed in accordance with ANSI/ASME OM-1-1987 (Ref. 5).

(continued)

SAN ONOFRE--UNIT 2 B 3.7-5 Amendment ýNo. +24

MSSVs B 3.7.1 BASES (continued)

SURVEILLANCE SR 3.7.1.1 (continued)

REQUIREMENTS According to Reference 5, the following tests are required for MSSVs:

a. Visual examination;

b. Seat tightness determination;

c. Setpoint pressure determination (lift setting); and

d. Compliance with owner"s seat tightness criteria.

This SR is modified by a Note that allows entry into and operation in MODE 3 prior to performing the SR. This is to allow testing of the MSSVs at hot conditions. The MSSVs may be either bench tested or tested in situ at hot conditions using an assist device to simulate lift pressure. If the MSSVs are not tested at hot conditions, the lift setting pressure shall be corrected to ambient conditions of the valve at operating temperature and pressure.

REFERENCES 1. UFSAR, Section 9--2 5

2. ASME, Boiler and Pressure Vessel Code,Section III, Article iNC-7000, Class 2 Components.

3. UFSAR, Section 15.2.

4. ASME, Boiler and Pressure Vessel Code,Section XI, Article IWV-3500.

5. ANSI/ASME OM-1-1987.

6. I NRC, NnfobInaiti'6h. Noti 'e-94"60'.

SAN ONOFRE--UNIT 2 B 3.7-6 Amendment No. 4-2-7-

v t e Letter Sequence Request
TAC:MD3584, Elimination of Hydrogen Recombiners and Change to Hydrogen and Oxygen Monitors (Approved, Closed) TAC:MD3585, MSSV Changes (Approved, Closed)
Initiation Request, Request Acceptance... Administration Questions Answers Results Approval, Approval, Approval Other: ML070610273
MONTHYEAR2006-12-20 [Table View]

ML063170129

Text

Subject:

SUBJECT:

1.0 INTRODUCTION

2.0 PROPOSED CHANGE

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

7.0 ENVIRONMENTAL CONSIDERATION

8.0 REFERENCES

1.0 INTRODUCTION

2.0 DESCRIPTION

3.0 BACKGROUND

4.0 TECHNICAL ANALYSIS

7.0 ENVIRONMENTAL CONSIDERATION

8.0 REFERENCES

7.0 ENVIRONMENTAL CONSIDERATION

8.0 REFERENCES

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