Text

Submittal of Amendment Applications 258 and 244, Technical Specifications Applicable to Movement of Fuel Assemblies
	ML100210200
Person / Time
Site:	San Onofre
Issue date:	01/14/2010
From:	Ridenoure R; Southern California Edison Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	PCN 593
	Download: ML100210200 (227)
	v • d • e

SOUTHERN CALIFORNIA Ross T. Ridenoure F 1 EuD _SSON _ _San Senior Vice President and CNO Onofre Nuclear Generating Station An EDISON INTERNATIONAL Company January 14, 2010 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington D.C. 20555-0001

Subject:

Docket Nos. 50-361 and 50-362 Amendment Applications 258 and 244 Technical Specifications Applicable to Movement of Fuel Assemblies San Onofre Nuclear Generating Station, Units 2 and 3

Reference:

NRC ADMINISTRATIVE LETTER 98-10, "Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety", December 29, 1998

Dear Sir or Madam:

Pursuant to 10 CFR 50.90, Southern California Edison (SCE) hereby submits license amendment applications 258 and 244 to operating licenses NPF-10 and NPF-15 for San Onofre Units 2 and 3, respectively. Amendment Applications 258 and 244 consist of the enclosed Proposed Change Number (PCN) 593.

Per 10 CFR 50 appendix B section XVI, Corrective Action, SCE has identified that the current applicability of several of the Technical Specifications is insufficient to assure plant safety. SCE implemented administrative controls in October 2008, in accordance with NRC Administrative Letter 98-10 (Referenced), to apply revised applicability until such time when the NRC completes its review and issues revised Technical Specification pages. As a corrective action to the identified deficiency, this proposed license amendment request provides new applicability language that includes the movement of non-irradiated fuel assemblies.

The Enclosure to this letter provides the Description and No Significant Hazards Consideration for the proposed amendments. SCE has determined that there is no significant hazards consideration associated with the proposed change and that the change is exempt from environmental review pursuant to the provisions of 10 CFR 51.22 (c) (9).

SCE requests approval of these proposed license amendments to be made effective upon issuance, and to be implemented within 60 days.

Mail Stop D45 P.O. Box 128 San Clemente, CA 92672 T D (949) 368-6255 PAX 86255 Fax: (949) 368-6183 A

-.. -4Z.

Ross. Ridenoure@sce.com

Document Control Desk January 14, 2010 A list of regulatory commitments associated with these proposed amendments is provided in the Enclosure.

If you have any questions or require any additional information, please contact Ms. Linda T. Conklin at (949) 368-9443.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: /- //'- /,9 (Date)

Sincerely,

Enclosure:

PCN-593 with Attachments

1. List of Regulatory Commitments

2. Proposed Technical Specifications Markup Pages, Unit 2

3. Proposed Technical Specifications Markup Pages, Unit 3

4. Proposed Technical Specifications Pages, Unit 2

5. Proposed Technical Specifications Pages, Unit 3

6. Proposed Technical Specifications Bases Markup Pages, Unit 2 (For Information Only)

7. Proposed Technical Specifications Bases Markup Pages, Unit 3 (For Information Only) cc: E. E. Collins, Regional Administrator, NRC Region IV R. Hall, NRC Project Manager, San Onofre Units 2 and 3 G. G. Warnick, NRC Senior Resident Inspector, San Onofre Units 2 and 3 S. Y. Hsu, California Department of Public Health, Radiologic Health Branch

ENCLOSURE EVALUATION OF THE PROPOSED CHANGE PCN-593 Movement of Fuel Assemblies

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION

3. TECHNICAL EVALUATION

4. REGULATORY SAFETY ANALYSIS 4.1. Applicable Regulatory Requirements/Criteria 4.2. Precedent 4.3. No Significant Hazards Consideration 4.4. Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES ATTACHMENTS:

1. List of Regulatory Commitments

2. Proposed Technical Specifications Markup Pages, Unit 2

3. Proposed Technical Specifications Markup Pages, Unit 3

4. Proposed Technical Specifications Pages, Unit 2

5. Proposed Technical Specifications Pages, Unit 3

6. Proposed Technical Specifications Bases Markup Pages, Unit 2 (For Information Only)

7. Proposed Technical Specifications Bases Markup Pages, Unit 3 (For Information Only)

Page 1 of 8

1.

SUMMARY

DESCRIPTION PCN-593 requests to amend Operating Licenses NPF-10 and NPF-15 for San Onofre Nuclear Generating Station (SONGS) Units 2 and 3, respectively.

This license amendment request will revise Technical Specifications (TS):

" LCO 3.3.8, "Containment Purge Isolation Signal (CPIS)"

LCO 3.3.9, "Control Room Isolation Signal (CRIS)"

LCO 3.7.11, "Control Room Emergency Air Cleanup System (CREACUS)"

" LCO 3.7.16, "Fuel Storage Pool Water Level"

" LCO 3.8.2, "AC Sources - Shutdown"

" LCO 3.8.5, "DC Sources - Shutdown"

" LCO 3.8.8, "Inverters - Shutdown"

LCO 3.8.10, "Distribution Systems - Shutdown"

" LCO 3.9.3, "Containment Penetrations"

" LCO 3.9.6, "Refueling Water Level" The proposed changes will revise the applicability of these Technical Specifications to add a new specified condition to the Applicability statement.

The proposed specified condition will apply to movement of any fuel assembly (irradiated or non-irradiated) over irradiated fuel assemblies in containment or the fuel storage pool. The added specific condition of movement of non-irradiated fuel assemblies is achieved by deleting the word "irradiated."

2. DETAILED DESCRIPTION This proposed change revises applicability wording regarding the movement of fuel assemblies in containment and in the fuel storage pool.

Containment Example:

LCO 3.3.8, "Containment Purge Isolation Signal (CPIS)":

[Existing] MODES 1, 2, 3, 4, During CORE ALTERATIONS, During movement of irradiated fuel assemblies within containment.

[New] MODES 1, 2, 3, 4, During CORE ALTERATIONS, During movement of fuel assemblies within containment.

Page 2 of 8

Fuel Storage Pool Example:

LCO 3.7.16, "Fuel Storage Pool Water Level":

[Existing] During movement of irradiated fuel assemblies in the fuel storage pool.

[New] During movement of fuel assemblies in the fuel storage pool.

Containment and Fuel Storage Pool Example:

LCO 3.7.11, "Control Room Emergency Air Cleanup System" (CREACUS)

[Existing] MODES 1, 2, 3, 4, 5, and 6, During movement of irradiated fuel assemblies

[New] MODES 1, 2, 3, 4, 5, and 6, During movement of fuel assemblies within containment, During movement of fuel assemblies in the fuel storage pool.

3. TECHNICAL EVALUATION

3.1 Background

In 1996 SONGS adopted Technical Specifications based on NUREG-1432, "Standard Technical Specifications - Combustion Engineering Reactors,"

September 1992. The current SONGS applicability statements are consistent with NUREG 1432, Revision 3.

The previous design analysis of record (Reference 1) for a failed fuel assembly in the fuel storage pool is 60 fuel rods which is the largest number of fuel rods that could fail from the worst postulated assembly drop. All 60 failed fuel rods were contained in the dropped assembly and the impacted assembly did not have any failed fuel rods. The original design analysis for failed fuel assemblies in the core is a maximum of 226 fuel rods which is the result of a vertical drop of a fuel assembly onto the fuel bundles in a partially loaded core.

Consequently, the existing SONGS Technical Specifications related to protection against the consequences of a Fuel Handling Accident are applicable during movement of irradiated fuel assemblies.

Page 3 of 8

3.2 Discussion A new analysis, "Updated SONGS 2 & 3 Fuel Assembly Drop Analysis of Record" (AOR) (Reference 2) was performed and has subsequently replaced the Fuel Bundle Drop Fuel Rod Failure Evaluation for SCE Units 2 & 3 (Reference 1). The AOR documents fuel rod damage predicted to result from horizontal and vertical drop scenarios in the fuel storage pool and the core.

Starting in 1995, fuel bundle weights increased due to changes in fuel assembly cladding. The new AOR (Reference 2) uses the heavier bundle weights and also includes the weights of components (i.e., CEA, neutron source, etc.), handling grapples, and a discretionary margin of 50 pounds which have not been accounted for in previous fuel assembly drop fuel rod failure analyses. The new conservative assembly drop weight is less than the maximum weight used to analyze the spent fuel racks and evaluate the spent fuel pool liner plate. Thus, the existing spent fuel rack and spent fuel pool liner plate analysis results remain applicable.

The updated analysis (Reference 2), calculates the predicted number of fuel rod failures for various fuel designs (standard and high density fuel pellets with zirconium based cladding) and for various fuel bundle weight combinations (bundle / discretionary weight / grapple weight). For fuel bundle drop scenarios in the fuel storage pool and core locations, the results of the updated analysis demonstrate that the maximum total number of fuel rods predicted to fail in the dropped and impacted fuel bundles is a total of 472 rods (this represents all fuel rods in both assemblies).

The control room and offsite dose consequences of 472 rods being failed were evaluated and determined to meet the 10 CFR 50.59 minimal dose increase criterion as defined in Regulatory Guide 1.187.

The existing Technical Specification applicability statements relevant to fuel movement refer to movement of irradiated fuel assemblies. The current applicability related to movement of fuel in the fuel storage pool is based in part on the assumption that no impacted fuel is damaged as a result of a dropped assembly. Under the existing SONGS Technical Specifications, movement of non-irradiated fuel assemblies is treated differently than movement of irradiated fuel assemblies because under the AOR, a dropped non-irradiated fuel assembly would not result in any radiological consequences in the fuel storage pool.

The Updated SONGS 2 & 3 Fuel Assembly Drop Analysis of Record shows that impacted fuel assemblies may be damaged as a result of a dropped assembly.

As a result, a drop of a non-irradiated fuel assembly could have radiological consequences. The applicability statements for the various Technical Specifications relevant to fuel movement should include movement of non-irradiated fuel assemblies (e.g., new fuel assemblies that have not been irradiated, or the dummy fuel assembly used for equipment testing).

Page 4 of 8

The current Technical Specifications are insufficient to assure plant safety because they are not applicable when moving non-irradiated fuel over irradiated fuel. Revising the applicability will ensure that those systems, structures, and components that are required by the Technical Specifications to protect against a Fuel Handling Accident are OPERABLE whenever there is a potential to damage irradiated fuel.

SCE is considering performing an additional analysis to determine if the current conclusion that impacted fuel would be damaged is overly conservative. Any such analysis, however, would not be completed within the next year.

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria Appendix A to Part 50 - General Design Criteria for Nuclear Power Plants VI. Fuel and Radioactivity Control Criterion 60--Control of releases of radioactive materials to the environment. The nuclear power unit design shall include means to control suitably the release of radioactive materials in gaseous and liquid effluents and to handle radioactive solid wastes produced during normal reactor operation, including anticipated operational occurrences. Sufficient holdup capacity shall be provided for retention of gaseous and liquid effluents containing radioactive materials, particularly where unfavorable site environmental conditions can be expected to impose unusual operational limitations upon the release of such effluents to the environment.

Criterion 61--Fuel storage and handling and radioactivity control. The fuel storage and handling, radioactive waste, and other systems which may contain radioactivity shall be designed to assure adequate safety under normal and postulated accident conditions. These systems shall be designed (1) with a capability to permit appropriate periodic inspection and testing of components important to safety, (2) with suitable shielding for radiation protection, (3) with appropriate containment, confinement, and filtering systems, (4) with a residual heat removal capability having reliability and testability that reflects the importance to safety of decay heat and other residual heat removal, and (5) to prevent significant reduction in fuel storage coolant inventory under accident conditions.

Criterion 62--Prevention of criticality in fuel storage and handling. Criticality in the fuel storage and handling system shall be prevented by physical systems or processes, preferably by use of geometrically safe configurations.

Page 5 of 8

Criterion 63--Monitoring fuel and waste storage. Appropriate systems shall be provided in fuel storage and radioactive waste systems and associated handling areas (1) to detect conditions that may result in loss of residual heat removal capability and excessive radiation levels and (2) to initiate appropriate safety actions.

Criterion 64--Monitoring radioactivity releases. Means shall be provided for monitoring the reactor containment atmosphere, spaces containing components for recirculation of loss-of-coolant accident fluids, effluent discharge paths, and the plant environs for radioactivity that may be released from normal operations, including anticipated operational occurrences, and from postulated accidents.

The proposed change does not affect any design features or processes related to fuel storage or radioactivity control.

4.2 PRECEDENT Based upon industry review and communications with the Technical Specifications Task Force that reports to the Pressurized Water Reactor Owners' Group and the Boiling Water Reactor Owners' Group, there is no related precedent.

4.3 No Significant Hazards Consideration Southern California Edison (SCE) has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the standards set forth in 10 CFR 50.92, issuance of Amendment, as discussed below:

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

Response: No.

This proposed change revises Technical Specifications applicability wording regarding the movement of fuel assemblies in containment and the fuel storage pool at the San Onofre Nuclear Generating Station (SONGS) Units 2 and 3 to include the movement of both irradiated and non-irradiated fuel assemblies. The proposed applicability is more comprehensive than the current Applicability.

Expanding the applicability of the relevant Technical Specifications is necessary to account for updated fuel drop analyses which demonstrate that impacted spent fuel assemblies may be damaged. Consequently, movement of non-irradiated fuel assemblies could result in a Fuel Handling Accident that has radiological consequences. Changing the applicability of the relevant Technical Specifications does not affect the probability of a Fuel Handling Accident. The Page 6 of 8

expanded applicability provides assurance that equipment designed to mitigate a Fuel Handling Accident is capable of performing its specified safety function, such that the consequences of an accident are not increased.

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

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

Response: No.

The revised spent fuel drop analyses demonstrate that impacted fuel assemblies may be damaged as the result of a dropped fuel assembly. The existing SONGS Technical Specifications regarding movement of fuel assemblies are not applicable for movement of non-irradiated fuel assemblies. A drop of a non-irradiated fuel assembly that has radiological consequences could occur during periods when equipment that would be required to mitigate those consequences is not required to be OPERABLE in accordance with the existing Technical Specifications.

The proposed changes to the Technical Specifications applicability language regarding the movement of fuel assemblies in containment and the fuel storage pool at SONGS Units 2 and 3 ensure that Limiting Conditions of Operation and appropriate Required Actions for required equipment are in effect during fuel movement. This provides assurance that any Fuel Handling Accident that may occur will remain within the initial assumptions of accident analyses.

Consequently, there is no possibility of a new or different kind of accident due to this change.

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

Response: No.

The proposed Technical Specifications change will not affect protection criterion for plant equipment and will not reduce the margin of safety. By extending the Applicability to the movement of non-irradiated fuel assemblies, the current margin of safety is maintained.

Consequently, there is no significant reduction in a margin of safety due to this change.

Page 7 of 8

Based on the above, SCE concludes that the proposed amendments present no significant hazards consideration under the substance set forth in 10 CFR 50.92 (c), and accordingly, a finding of no significant hazards consideration is justified.

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions' regulations, and (3) the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.

5. ENVIRONMENTAL CONSIDERATION The proposed amendment does not change any requirements with respect to the installation of or use of a facility component located within the restricted area, as defined in 10 CFR 20, or change any inspection or surveillance requirement. The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amount of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22 (c) (9). Therefore, pursuant to 10 CFR 51.22 (b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. S023-990-C437, Revision 0, Fuel Bundle Drop Evaluation for SCE Units 2&3

2. S023-990-C467, Revision 0, Updated SONGS 2 & 3 Fuel Assembly Drop Analysis of Record Page 8 of 8

PCN-593 Attachment 1 List of Regulatory Commitments

PCN-593 List of Regulatory Commitments The following table identifies the regulatory commitment in this document. Any other statements in this submittal represent intended or planned actions. They are provided for information purposes and are not considered to be regulatory commitments.

TYPE SCHEDULED Continuing COMPLETION DATE COMMITMENT One-time Compliance (if applicable)

1) SONGS will continue to implement revised Until NRC applicability of Technical Specifications that completes its are pertinent to the movement of fuel Review and assemblies using administrative controls in X issues Revised accordance with NRC Administrative Letter Technical 98-10. Specification Pages Page 1 of 1

Enclosure:

Evaluation of Proposed Change PCN-593 Attachment 2 Proposed Technical Specifications Markup Pages, Unit 2

CPIS 3.3.8 3.3 INSTRUMENTATION 3.3.8 Containment Purge Isolation Signal (CPIS)

LCO 3.3.8 One CPIS channel shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4, During CORE ALTERATIONS, During movement of i-rradi-ated fuel assemblies within containment.

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

Only required-when the penetration is not isolated by appropriate closed and de-activated automatic valve(s),

closed manual valve(s), or blind flange(s).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. CPIS Actuation Logic, A.1 Enter applicable Immediately or one or more Conditions and required channels of Required Actions for containment airborne affected valves of radiation monitors LCO 3.6.3, inoperable in MODES 1, "Containment 2, 3, and 4. Isolation Valves,"

made inoperable by CPIS instrumentation.

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 in AND MODES 1,.2, 3, or 4.

B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

SAN ONOFRE--UNIT 2 3.3-35 Amendment No. o2,1-32

CPIS 3.3.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more required C.I Enter applicable Immediately channels of conditions and containment airborne required actions of radiation monitors LCO 3.4.15, "RCS Leak inoperable in MODES 1, Detection."

2, 3, and 4.

NOTE---------

D. CPIS Manual Trip, The provisions of LCO 3.0.3 Actuation Logic, or are not applicable.

one or more required channels of D.1 Place and maintain Immediately containment airborne containment purge radiation monitors supply and exhaust inoperable during CORE valves in closed ALTERATIONS or position.

movement of irradiated fuel assemblies within OR containment.

D.2.1 Suspend CORE Immediately ALTERATIONS.

AND D.2.2 Suspend movement of Immediately ir efuel assemblies in containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.8.1 Perform a CHANNEL CHECK on required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months containment airborne radiation monitor channel.

(continued)

SAN ONOFRE--UNIT 2 3.3-36 Amendment No. 1+/-2,13*

CRIS 3.3.9 3.3 INSTRUMENTATION 3.3.9 Control Room Isolation Signal (CRIS)

LCO 3.3.9 One CRIS channel shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, Durn movement of irrad-iat-ed fuel assemblies within -

con Do ami nethv*m he fuel storage pool.

During movement of fuel assemblies in th fuel stoae ol ACTIONS

NOTES------------------------

1. The provisions of LCO 3.0.3 are not applicable.

2. The provisions of LCO 3.0.4 are not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. CRIS Manual Trip, A.1 ---------NOTE-------

Actuation Logic, or Place Control Room one required channel Emergency Air Cleanup of control room System (CREACUS) in airborne radiation isolation mode if monitors inoperable in automatic transfer to MODES 1, 2, 3, or 4. isolation mode inoperable.

Place one CREACUS 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months train in emergency.

mode.

(continued)

SAN ONOFRE--UNIT 2 3.3-39 Amendment No. 127,132

CRIS 3.3.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. CRIS Manual Trip, B.1 - -------- NOTE-------

Actuation Logic, or Place CREACUS in required control room isolation mode if airborne radiation automatic transfer to monitors inoperable in isolation mode MODE 5 or 6, or during inoperable.

movement of containmen , or during Sthe movement of fuel Place one CREACUS Immediately assemblies within the/ train in emergency mode.

OR B.2.1 Suspend movement of Immediately t fuediatoa fuel B.2.2AND Sus--

- NOTE- -----

I ,mq*~flI nlen+/- rtnnrnl Immediately operations are allowed provided the changes are accounted for in the calculated SDM.

Suspend positive reactivity additions.

______________________________ L I ___________________

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.9.1 Perform a CHANNEL CHECK on the required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months control room airborne radiation monitor channel.

(continued)

SAN ONOFRE--UNIT 2 3.3-40 Amendment No. 132,175

I CREACUS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Emergency Air Cleanup System (CREACUS)

LCO 3.7.11 Two CREACUS trains shall be OPERABLE.

NOTE---

The control room envelope (CRE) boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, During movement of fuel assemblies in the fuel storage pool.

ACTIONS ------ ---- --- ---NOT ES - - - - - - - - - - - - - - -

1. The provisions of LCO 3.0.4 are not applicable when entering MODES 5, 6, or defueled configuration.

2. Each Unit shall enter applicable ACTIONS separately.

CONDITION REQUIRED ACTION COMPLETION TIME A. One CREACUS train A.1 Restore CREACUS train 14 days inoperable for reasons to OPERABLE status.

other than Condition B.

B. One or more CREACUS B.1 Initiate action to Immediately trains inoperable due implement mitigating to inoperable CRE actions.

boundary in Modes 1, AND 2, 3, or 4.

B.2 Verify mitigating 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.

AND B.3 Restore CRE boundary 90 days to OPERABLE status.

(continued)

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

CREACUS 3.7.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or AND B not met in MODE 1, 2, 3, or 4. C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months D. Required Action and D.1 Place OPERABLE Immediately associated Completion CREACUS train in Time of Condition A not emergency radiation met in MODE 5 or 6, or protection mode.

during movement of irradatedOR containmen , or during D.2.1 Suspend CORE Immediately the movement of fuelALTERATIONS.

assemblies within the AND D.2.2 Suspend movement of Immediately irdiated assemblies within on ainment.

D.2.3

~fuel Suspend movement of assembliesein Immediatel fuel. storage

~~theol SAN ONOFRE--UNIT 2 3.7-25 Amendment No. H4

CREACUS 3.7.11 ACTIONS (continued)

E. Two CREACUS trains E.1 Suspend CORE Immediately inoperable in MODE 5 ALTERATIONS.

or 6, or during movement of irradiated AND E.2 Immediately fulassemblies wnithinue f

f^CREACUS.ue! I E.3 Suspend movement of imediately One or '-more trains inoperable due fuel assemblies in to an inoperable

assemblies i~nthe iRE fuel* the fuel storage boundary in MODE 5 or 6, or during movement (conti nued)

SAN ONOFRE--UNIT 2 3.7-25a Amendment No. 2-+4

Fuel Storage Pool Water Level 3.7.16 3.7 PLANT SYSTEMS 3.7.16 Fuel Storage Pool Water Level LCO 3.7.16 The fuel storage pool water level shall be 2 23 ft over the top of irradiated fuel assemblies seated in the storage racks.

APPLICABILITY: During movement of irradiated fuel assemblies in the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel storage pool A.1 ---------NOTE-------

water level not within LCO 3.0.3 is not limit. applicable.

Suspend movement of Immediately i-radiated fuel assemblies in fuel storage pool.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.16.1 Verify the fuel storage pool water level is 7 days

Ž 23 ft above the top of irradiated fuel assemblies seated in the storage racks.

SAN ONOFRE--UNIT 2 3.7-29 Amendment No. +F

AC Sources - Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources-Shutdown, LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:

a. One qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems Shutdown"; and

b. One diesel generator (DG) capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10.

APPLICABILITY: MODES 5 and 6, .

'nmvmetO -rfadia--ted fuel as sembl es wi thi n "-

During movement of fuel assemblies in the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite ----------- NOTE----------

circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized as a result of Condition A.

A.1 Declare affected Immediately required feature(s) with no offsite power available inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND (continued)

SAN ONOFRE--UNIT 2 3.8-17 Amendment No. +H

AC Sources- Shutdown 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.2 Suspend movement of Immediately assemblies within o0 ainment.

Immediately theAfuel storag ool.

AN__DD A.2. 4Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron Immediately concentration.

AND A.2,*ý Initiate action to restore required offsite power circuit to OPERABLE status.

SAN ONOFRE--UNIT 2 3.8-18 Amendment No. 127,175

AC Sources- Shutdown 3.8.2 CONDITION I REQUIRED ACTION COMPLETION TIME B. One required DG B.I Suspend CORE Immedi ately inoperable. ALTERATIONS.

AND B.2 Suspend movement of Immediately irradiated f el assemblies within cont~ai nment.

ýB.3 Suspend movement of)

, ~fuel assemblies in L--L the fuel storage2 AN D Immediately B.-3' Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND Immediately Initiate action to restore required DG to OPERABLE status.

SAN ONOFRE--UNIT 2 3.8-18a Amendment No. 127,175

DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources Shutdown LCO 3.8.5 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subs stem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown."

APPLICABILITY: MODES 5 and 6 ACTIONS

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

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. --------- NOTE -------- A.1 Restore battery 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months terminal voltage to Only applicable to greater than or equal 1800 amp-hour rated to the minimum batteries, established float voltage.

AND One or two required battery charger(s) on A.2 Verify battery float Once per 12 one train inoperable, current < 1.50 amps. hours AND A.3.1 Restore required 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months battery charger(s) to OPERABLE status.

OR A.3.2.1 Provide ability to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ower the spare attery charger from a diesel-backed source.

AND A.3.2.2 Restore required 7 days battery charger(s) to OPERABLE status.

(continued)

SAN ONOFRE--UNIT 2 3.8-27 Amendment No. 2-1-8

DC Sources - Shutdown 3.8.5 CONDITION 1 REQUIRED ACTION I COMPLETION TIME D. One or more required D.I Declare affected Immediately DC electrical power required feature(s) subsystem(s) inoperable inoperable for reasons other than Conditions OR A or B.

D.2.1 Sus pend CORE Immediately ALTERATIONS AND D.2.2 Suspend movement of Immediately assemblies wit in t--c 4onmainýhmenr-ý th fe ftoag1.

Immediately AND D.2. ) Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND D..2.5 Initiate.action to Immediately restore required DC electrical power subsystem(s) to OPERABLE status.,

SAN ONOFRE--UNIT 2 3.8-28 Amendment No. 24ý'

Inverters- Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters -Shutdown LCO 3.8.8 Required inverters shall be OPERABLE to support the onsite Class 1E AC vital bus electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown."

APPLICABILITY: MODES 5 and 6, Durnn rvement of i-rrad-iat-ed fuel assemblies within on amine Duri ng movement of fuel assembl ies in the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare affected Immediately inverters inoperable. required feature(s) inoperable.

OR A.2.1 Sus pend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately

+radated fuel a ssemmIee sýWith in) n0tai niment .

! of end movement Susueassembl Immediately ZA.2.3 iee j the fuel sto~rage AND A.2.30 Suspend operations involving positive Immediately reactivity additions that could result in loss of required SDM or boron concentration.

AND (continued)

SAN ONOFRE--UNIT 2 3.8-36 Amendment No. 121 Inverters- Shutdown 3.8.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.4) Initiate action to Immediately restore required inverters to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct inverter voltage and 7 days alignment to required AC vital buses.

SAN ONOFRE--UNIT 2 3.8-37 Amendment No. +2-ý

Distribution Systems - Shutdown 3.8.10 3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems - Shutdown LCO 3.8.10 The necessary portion of AC, DC, and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE APPLICABILITY: MODES Duri'm 5movement and 6. of ii-I-adiated fuel assemblies within na m m-nv t of f uel as emblie s with

. i movement During 1 L of fuel assemblies in the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare associated Immediately AC, DC, or AC vital supported required bus electrical power feature(s) inoperable.

distribution systems inoperable. OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately IrII-di-ated fuel s s emb I *e s * ýin c~ontainmen

(

AND A.2.3Suspend operations Immedi ately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND (continued)

J U SAN ONOFRE--UNIT 2 3.8-40 Amendment No. 1ý

Distribution Systems - Shutdown 3.8.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.4J Initiate actions to Immediately restore required AC, DC, and AC vital bus electrical power distribution system(s) to OPERABLE status.

AND A.2.C3 Declare associated Immediately required shutdown cooling system(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.10.1 Verify correct breaker alignments and 7 days voltage to required AC, DC, and AC vital bus electrical power distribution systems.

SAN ONOFRE--UNIT 2 3.8-41 Amendment No. 2+8

Containment Penetrations 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Containment Penetrations LCO 3.9.3 The containment penetrations shall be in the following status:

a. The equipment hatch closed and held in place by four bolts;

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

The equipment hatch may be open if all of the following conditions are met:

1) The Containment Structure Equipment Hatch Shield Doors are capable of being closed within 30 minutes,

2) The plant is in Mode 6 with at least 23 feet of water above the reactor vessel flange,

3) A designated crew is available to close the Containment Structure Equipment Hatch Shield Doors,

4) Containment purge is in service, and

5) The reactor has been subcritical for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

b. One door in each air lock closed;

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

Both doors of the containment personnel airlock may be open provided:

a. one personnel airlock door is OPERABLE, and bl. the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel, or b2. defueled configuration with fuel in containment (i.e., fuel in refueling machine or upender).

c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either:

1. closed by a manual or automatic isolation valve, blind flange, or equivalent, or

2. capable of being closed by an OPERABLE Containment Purge System.

APPLICABILITY: During CORE ALTERATIONS, During movement of i-rra-d-iaed fuel assemblies within containment.

SAN ONOFRE--UNIT 2 3.9-4 Amendment No. 127,193

Containment Penetrations 3.9.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Suspend CORE Immediately containment ALTERATIONS.

penetrations not in required status. AND A.2 Suspend movement of Immediately ra-di-a+e- fuel assemblies within containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.3.1 Verify each required containment 7 days penetration is in the required status.

SR 3.9.3.2 Verify each required containment purge and 24 months exhaust valve actuates to the isolation position on an actual or simulated actuation signal.

SAN ONOFRE--UNIT 2 3.9-5 Amendment No. 127,193

Refueling Water Level 3.9.6 3.9 REFUELING OPERATIONS 3.9.6 Refueling Water Level LCO 3.9.6 Refueling water level shall be maintained Ž 23 ft above the top of reactor vessel flange.

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

Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs, coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling.

APPLICABILITY: During movement of fuel assemblies or CEAs within the reactor pressure vessel whe either the fuel asse..blies

- FIR FRRi0- A Al

ý b L,

4. -r 1 A Q - -- I- II ii. - , Q Q - ;14: - A Fi

h 4 n :ý k - 'A -A P* R I-ljý-.' 4I 't, I-I v "1'*,.U

ý;; -* . .I *l ý- . *,

U , ,..IU v

ý .

pressure vessel are irradiated, During movement of +rrdi-ate fuel assemblies within containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Refueling water level A.1 Suspend CORE Immediately not within limit. ALTERATIONS.

AND A.2 Suspend movement of Immediately adi-ted fuel assemblies within containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 The refueling water level shall be 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months determined to be at least its minimum required depth.

SAN ONOFRE--UNIT 2 3.9-10 Amendment No. 127, 134

Enclosure:

Evaluation of Proposed Change PCN-593 Attachment 3 Markup Pages, Unit 3 Proposed Technical Specifications

CPIS 3.3.8 3.3 INSTRUMENTATION 3.3.8 Containment Purge Isolation Signal (CPIS)

LCO 3.3.8 One CPIS channel shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4, During CORE ALTERATIONS, During movement of irradiated fuel assemblies within containment.

----- NOTE Only required when the penetration is not isolated by appropriate closed and de-activated automatic valve(s),

closed manual valve(s), or blind flange(s).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. CPIS Actuation Logic, A.1 Enter applicable Immediately or one or more Conditions and required channels of Required Actions for containment airborne affected valves of radiation monitors LCO 3.6.3, inoperable in MODES I, "Containment 2, 3, and 4. Isolation Valves,"

made inoperable by CPIS instrumentation.

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 in AND MODES 1, 2, 3, or 4.

B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

SAN ONOFRE--UNIT 3 3.3-35 Amendment No. 1i-6,-2

CPIS 3.3.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more required C.1 Enter applicable Immediately channels of conditions and containment airborne required actions of radiation monitors LCO 3.4.15, "RCS Leak inoperable in MODES 1, Detection."

2, 3, and 4.

NOTE---------

D. CPIS Manual Trip, The provisions of LCO 3.0.3 Actuation Logic, or are not applicable.

one or more required channels of D.1 Place and maintain Immediately containment airborne containment purge radiation monitors supply and exhaust inoperable during CORE valves in closed ALTERATIONS or position.

movement of irradiated fuel assemblies within OR containment.

D.2.1 Suspend CORE Immediately ALTERATIONS.

AND D.2.2 Suspend movement of Immediately irradiated fuel assemblies in containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.8.1 Perform a CHANNEL CHECK on required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months containment airborne radiation monitor channel.

(continued)

SAN ONOFRE--UNIT 3 3.3-36 Amendment No. I6,-1-2

CRIS 3.3.9 3.3 INSTRUMENTATION 3.3.9 Control Room Isolation Signal (CRIS)

LCO 3.3.9 One CRIS channel shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, ACTIONS

NOTES------------------------

1. The provisions of LCO 3.0.3 are not applicable.

2. The provisions of LCO3.0.4 are not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. CRIS Manual Trip, A.1 ---------- NOTE-------

Actuation Logic, or Place Control Room one required channel Emergency Air Cleanup of control room System (CREACUS) in airborne radiation isolation mode if monitors inoperable in automatic transfer to MODES 1, 2, 3, or 4. isolation mode inoperable.

Place one CREACUS I hour train in emergency mode.

(continued)

SAN ONOFRE--UNIT 3 3.3-39 Amendment No. 116,121

CRIS 3.3.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B, CRIS Manual Trip, B.1 NOTE------- --------

Actuation Logic, or Place CREACUS in required control room isolation mode if.

airborne radiation automatic transfer to monitors inoperable in isolation mode MODE 5 or 6, or during inoperable.

movement of ntains~meentb, or during/

the movement of fuel Place one CREACUS Immediately

\a ssemblies withi n the/ train in emergency mode.

OR B.2.1 Suspend movement of Immediately irradiated fuel assemblies in ANDfuel semblie i AND B.2. NOTE------- --------

Limited plant control Immediately operations are allowed provided the changes are accounted for in the calculated SDM.

Suspend positive reactivity additions.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.9.1 Perform a CHANNEL CHECK on the required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months control room airborne radiation monitor channel.

(continued)

SAN ONOFRE--UNIT 3 3.3-40 Amendment No. 21,*-66

CREACUS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Emergency Air Cleanup System (CREACUS)

LCO 3;7.11 Two CREACUS trains shall be OPERABLE.

NOTE The control room envelope (CRE) boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, ACTIONS 1. The provisions of LCO 3.0.4 are not applicable when entering MODES 5, 6, or defueled configuration.

2. Each Unit shall enter applicable ACTIONS separately.

CONDITION REQUIRED ACTION COMPLETION TIME A. One CREACUS train A.1 Restore CREACUS train 14 days inoperable for to OPERABLE status.

reasons other than Condition B.

B. One or more CREACUS B.1 Initiate action to Immediately trains inoperable due implement mitigating to inoperable CRE actions.

boundary in Modes 1, 2, 3, or 4. AND B.2 Verify mitigating 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.

AND B.3 Restore CRE boundary 90 days to OPERABLE status.

(continued)

SAN ONOFRE--UNIT 3 3.7-24 Amendment No. 24&

CREACUS 3.7.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or AND B not met in MODE 1, 2, 3, or 4. C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months D. Required Action and D.1 Place OPERABLE Immediately associated Completion CREACUS train in Time of Condition A not emergency radiation met in MODE 5 or 6, or protection mode.

during movement of

+rradi fu 1 OR asembIi es ithin n ~a-nment, or duringng D,2,1 Suspend CORE Immediately 7the movement of fuel ALTERATIONS.

assemblies within the AND D.2.2 Suspend movement of Immediately ulful D.2.3 Suspend movement of Immediately fuel assemblies in the fuel storage pool.

SAN ONOFRE--UNIT 3 3.7-25 Amendment No. H6

CREACUS 3.7.11 ACTIONS E. Two CREACUS trains Suspend CORE Immediately inoperable in MODE 5 ALTERATIONS.

or 6, or during movement of -irft4-i-~ed% fuel AND Sthe movement of fuel Suspend movement of Immediately

-rradiated fuel assemblies in the )fuelI .assemblies withi

" storage. pool. - co~ntainment.

AND UK

,E.3 Suspend movement of Immediately One or more CREACUS fuel assemblies in trains inoperable due to inoperable CRE boundary the fuel storage in MODES5 or 6, or pool .

during movement of ofuel

the movement of fuel Sassemblies in the fuel/

(conti nued)

I SAN ONOFRE--UNIT 3 3-7-25a Amendment No. 2%

Fuel Storage Pool Water Level 3.7.16 3.7 PLANT SYSTEMS 3.7.16 Fuel Storage Pool Water Level LCO 3.7.16 The fuel storage pool water level shall be Ž 23 ft over the top of irradiated fuel assemblies seated in the storage racks.

APPLICABILITY: During movement of irradiated fuel assemblies in the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel storage pool A.1 -------- NOTE-------

water level not within LCO 3.0.3 is not limit. applicable.

Suspend movement of Immediately Irradiatýd fuel assemblies in fuel storage pool.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.16.1 Verify the fuel storage pool water level is 7 days

Ž 23 ft above the top of irradiated fuel assemblies seated in the storage racks.

SAN ONOFRE--UNIT 3 3.7-29 Amendment No. ++6

AC Sources- Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources-Shutdown LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:

a. One qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems Shutdown"; and

b. One diesel generator (DG) capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10.

APPLICABILITY: MODES 5 and 6, ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite ----- NOTE----------

circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized as a result of Condition A.

A.1 Declare affected Immediately required feature(s) with no offsite power available inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND (continued)

SAN ONOFRE--UNIT 3 3.8-17 Amendment No. 1+&

AC Sources- Shutdown 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.2 Suspend movement of Immediately A..3 Supndmoemn o Imdiatelyfu afuel ssemblies in

~the fuel storage AND A.2.*4, Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

A.2.43AND Initiate action to Immediately restore required offsite power circuit to OPERABLE status.

SAN ONOFRE--UNIT 3 3.8-18 Amendment No. 11-6,66

AC Sources-.Shutdown 3.8.2 CONDITION REQUIRED ACTION COMPLETION TIME B. One required DG B.I Suspend CORE Immedi atel y inoperable. ALTERATIONS.

AND B.2 Suspend movement of Immediately i-rradiate4 fuel B.3 Suspend movement ino fuel assemblies the fuel storage pool.

AND Immedi ately Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND Immediately B A) Initiate action to restore required DG to OPERABLE status.

SAN ONOFRE--UNIT 3 3.8-19 Amendment No. 116,166

DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources Shutdown LCO 3.8.5 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown."

APPLICABILITY: MODES 5 and 6, Dunin ni-ei

o. gt of +1fd-i-ate4 fuel assembl ies ithiin ontainment, gDuri ng movement of fuel assembl ies in the fuel storage pool .

ACTIONS

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

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A ------ NOTE --------- A.1 Restore battery 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months terminal voltage to Only applicable to greater than or equal 1800 amp-hour rated to the minimum batteries, established float voltage.

AND One or two required battery charger(s) on A.2 Verify battery float Once per 12 one train inoperable, current _51.50 amps. hours AND A.3.1 Restore required 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months battery charger(s) to OPERABLE status.

OR A.3.2.1 Provide ability to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ower the spare attery charger from a diesel-backed source.

AND A.3.2.2 Restore required 7 days battery charger(s) to OPERABLE status.

(continued)

SAN ONOFRE--UNIT 3 3.8-27 Amendment No. H+

DC Sources - Shutdown 3.8.5 CONDITION REQUIRED ACTION J COMPLETION TIME D. One or more required D.I Declare affected Immediately DC electrical power required feature(s) subsystem(s) inoperable.

inoperable for reasons other than Condition A OR or B.

D.2.1 Suspend CORE Immediately ALTERATIONS.

AND D.2.2 Suspend movement of Immediately assem s i hin

,Immediately

,D.2.3 Suspend movement of

~~uel assemblies ienr the fuel storage DOI.

AND Immediately D.2.P Suspend operations involving positive.

reactivity additions that could result in loss of required SDM or boron concentration.

AN__OD D.,2 .0 Immedi ately Initiate action to restore required DC electrical power subsystem(s) to OPERABLE status.

SAN ONOFRE--UNIT 3 3.8-28 Amendment No. H4

Inverters- Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters -Shutdown LCO 3.8.8 Required inverters shall be OPERABLE to support the onsite Class 1E AC vital bus electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems- Shutdown."

APPLICABILITY: MODES 5 and 6, Durnnl mo Lement (of irraiated~e fuel assemblies within con ainmeinf During movem~ent of fuel assemblies in the fuel storage pool.

ACTIONS CONDITION I REQUIRED ACTION COMPLETION TIME A. One or more required A.I Declare affected Immediately inverters inoperable. required feature(s) inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately iIrrIrd-iated fuel a.ssembl ies WT7i ýh" A.2.3 Sus pend movement of fuel assemblies in L-1* the fuel storage pool.

AND A. 2 .V Immediately Suspend operations involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND (continued)

SAN ONOFRE--UNIT 3 3.8-36 Amendment No. 116,166

Inverters- Shutdown 3.8.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.J Initiate action to Immediately restore required inverters to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct inverter voltage and 7 days alignment to required AC vital buses.

SAN ONOFRE--UNIT 3 3.8-37 Amendment No. +-1-6

Distribution Systems - Shutdown 3.8.10 3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems - Shutdown LCO 3.8.10 The necessary portion of AC, DC, and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE.

APPLICABILITY: MODES 5 and 6.

S the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.I Declare associated Immediately AC, DC, or AC vital supported required bus electrical power feature(s) inoperable.

distribution systems inoperable. OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately irradiat uel assemblies Cwi hin co 1ainnmenf A.2.3 Suspend movement of Immediately

fuel assemblies in the AND A.2. tSuspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND (conti nued)

SAN ONOFRE--UNIT 3 3.8-40 Amendment No. 2-H

Distribution Systems - Shutdown 3.8.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2. Initiate actions to Immediately restore required AC, DC, and AC vital bus electrical power distribution system(s) to OPERABLE status.

AND A.2. 4 60 Declare associated Immediately required shutdown cooling system(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.10.1 Verify correct breaker alignments and 7 days voltage to required AC, DC, and AC vital bus electrical power distribution systems.

SAN ONOFRE--UNIT 3 3.8-41 Amendment No. 2-1-1

Containment Penetrations 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Containment Penetrations LCO 3.9.3 The containment penetrations shall be in the following status:

a. The equipment hatch closed and held in place by four bolts;

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

The equipment hatch may be open if all of the following conditions are met:

i) The Containment Structure Equipment Hatch Shiel-d Doors are capable of being closed within 30 minutes,

2) The plant is in Mode 6 with at least 23 feet of water above the reactor vessel flange,

3) A designated crew is available to close the Containment Structure Equipment Hatch Shield Doors,

4) Containment purge is in service, and

5) The reactor has been subcritical for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

b. One door in each air lock closed;

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

Both doors of the containment personnel airlock may be open provided:

a. one personnel airlock door is OPERABLE, and bl. the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel, or b2. defueled configuration with fuel in containment (i.e., fuel in refueling machine or upender).

c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either:

1. closed by a manual or automatic isolation valve, blind flange, or equivalent, or

2. capable of being closed by an OPERABLE Containment Purge System.

APPLICABILITY: During CORE ALTERATIONS, During movement of irr~-d-*-dfuel assemblies within containment.

SAN ONOFRE--UNIT 3 3.9-4 Amendment No. 116,184

Containment Penetrations 3.9.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Suspend CORE Immediately containment ALT ERATIONS.

penetrations not in required status. AND A.2 Suspend movement of

-i-r Immediately ed fuel assemblies within containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.3.1 Verify each required containment 7 days penetration is in the required status.

SR 3.9.3.2 Verify each required containment purge and 24 months exhaust valve actuates to the isolation position on an actual or simulated actuation signal.

SAN ONOFRE--UNIT 3 3.9-5 Amendment No. 116,184

Refueling Water Level 3.9.6 3.9 REFUELING OPERATIONS 3.9.6 Refueling Water Level LCO 3.9.6 Refueling water level shall be maintained ; 23 ft above the top of reactor vessel flange.

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

Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs, coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling.

APPLICABILITY: During movement of fuel assemblies or CEAs within the reactor pressure vessel when eithei the fuel assemblies -I ---

-md flve bi- ti~e Tuel d a -1i-11 DeII S Z UUca U VY jI1111I I I -- I1-V of Z IaUUmbie fIuI tLhUn, uring movement of +irra~diated fuel assemblies within containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Refueling water level A.1 Suspend CORE Immediately not within limit. ALTERATIONS.

AND A.2 Suspend movement of Immediately

-fuel assemblies within containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 The refueling water level shall be 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months determined to be at least its minimum required depth.

SAN ONOFRE--UNIT 3 3.9-10 Amendment No. 116, 123-

Enclosure:

Evaluation of Proposed Change PCN 593 Attachment 4 Proposed Technical Specification Pages, Unit 2

CPIS 3.3.8 3.3 INSTRUMENTATION 3.3.8 Containment Purge Isolation Signal (CPIS)

LCO 3.3.8 One CPIS channel shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4, During CORE ALTERATIONS, During movement of fuel assemblies within containment.

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

Only required when the penetration is not isolated by appropriate closed and de-activated automatic valve(s),

closed manual valve(s), or blind flange(s).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. CPIS Actuation Logic, A.1 Enter applicable Immediately or one or more Conditions and required channels of Required Actions for containment airborne affected valves of radiation monitors LCO 3.6.3, inoperable in MODES 1, "Containment 2, 3, and 4. Isolation Valves,"

made inoperable by CPIS instrumentation.

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 in AND MODES 1, 2, 3, or 4.

B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

SAN ONOFRE--UNIT 2 3.3-35 Amendment No.

CPIS 3.3.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more required C.1 Enter applicable Immediately channels of conditions and containment airborne required actions of radiation monitors LCO 3.4.15, "RCS Leak inoperable in MODES 1, Detection."

2, 3, and 4.

NOTE----------

D. CPIS Manual Trip, The provisions of LCO 3.0.3 Actuation Logic, or are not applicable.

one or more required channels of D.1 Place and maintain Immediately containment airborne containment purge radiation monitors supply and exhaust inoperable during CORE valves in closed ALTERATIONS or position.

movement of fuel assemblies within OR containment.

D.2.1 Suspend CORE Immediately ALTERATIONS.

AND D.2.2 Suspend movement of Immediately fuel assemblies in containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.8.1 Perform a CHANNEL CHECK on required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months containment airborne radiation monitor channel.

(continued)

SAN ONOFRE--UNIT 2 3.3-36 Ampndmpnt Nn.

CRIS 3.3.9 3.3 INSTRUMENTATION 3.3.9 Control Room Isolation Signal (CRIS)

LCO 3.3.9 One CRIS channel shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, During movement of fuel assemblies within containment, During movement of fuel assemblies in the fuel storage pool.

ACTIONS

NOTES------------------------

1. The provisions of LCO 3.0.3 are not applicable.

2. The provisions of LCO 3.0.4 are not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. CRIS Manual Trip, A.1 ---------NOTE-------

Actuation Logic, or Place Control Room one required channel Emergency Air Cleanup of control room System (CREACUS) in airborne radiation isolation mode if monitors inoperable in automatic transfer to MODES 1, 2, 3, or 4. isolation mode inoperable.

Place one CREACUS 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months train in emergency mode.

(continued)

SAN ONOFRE--UNIT 2 3.3-37 Ampndmpnt No.

CRIS 3.3.9 ACTIONS (continued)

CONDITION I REQUIRED ACTION COMPLETION TIME B. CRIS Manual Trip, B.1 - --------

NOTE-------

Actuation Logic, or Place CREACUS in required control room isolation mode if airborne radiation automatic transfer to monitors inoperable in isolation mode MODE 5 or 6, or during inoperable.

movement of fuel assemblies within containment, or during Place one CREACUS Immediately the movement of fuel train in emergency assemblies within the mode.

fuel storage pool.

OR B.2.1 Suspend movement of Immediately fuel assemblies within containment.

AND B.2.2 Suspend movement of Immediately fuel assemblies in the fuel storage pool.

AND B.2.3 ---------NOTE------- Immediately Limited plant control operations are allowed provided the changes are accounted for in the calculated SDM.

Suspend positive reactivity additions.

SURVEILLANCE REQUIREMENTS SAN ONOFRE--UNIT 2 3.3-38 Amendment No.

CRIS 3.3.9 ACTIONS (continued)

SURVEILLANCE FREQUENCY SR 3.3.9.1 Perform *aCHANNEL CHECK on the required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months control room airborne radiation monitor channel.

(continued)

SAN ONOFRE--UNIT 2 3.3-39 Amendment No.

CREACUS 3.7.11 3.7 PLANTSYSTEMS 3.7.11 Control Room Emergency Air Cleanup System (CREACUS)

LCO 3.7.11 Two CREACUS trains shall be OPERABLE.

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

The control room envelope (CRE) boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, During movement of fuel assemblies within containment, During movement of fuel assemblies in the fuel storage pool.

ACTIONS ------------------------ NOTES--------------------------

1. The provisions of LCO 3.0.4 are not applicable when entering MODES 5, 6, or defueled configuration.

2. Each Unit shall enter applicable ACTIONS separately.

CONDITION REQUIRED ACTION COMPLETION TIME A. One CREACUS train A.1 Restore CREACUS train 14 days inoperable for reasons to OPERABLE status.

other than Condition B.

B. One or more CREACUS B.1 Initiate action to Immediately trains inoperable due implement mitigating to inoperable CRE actions.

boundary in Modes 1, 2, 3, or 4. AND B.2 Verify mitigating 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.

AND B.3 Restore CRE boundary 90 days to OPERABLE status.

(continued)

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

CREACUS 3.7.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or AND B not met in MODE 1, 2, 3, or 4. C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months D. Required Action and D.1 Place OPERABLE Immediately associated Completion CREACUS train in Time of Condition A not emergency radiation met in MODE 5 or 6, or. protection mode.

during movement of fuel assemblies within OR containment, or during the movement of fuel D.2.1 Suspend CORE Immediately assemblies within the ALTERATIONS.

fuel storage pool.

AND D.2.2 Suspend movement of Immediately fuel assemblies within containment.

AND D.2.3 Suspend movement of Immediately fuel assemblies in the fuel storage pool.

SAN ONOFRE--UNIT 2 3.7-25 Amendment No.

CREACUS 3.7.11 ACTIONS (continued)

E. Two CREACUS trains E.1 Suspend CORE Immediately inoperable in MODE 5 ALTERATIONS.

or 6, or during movement of fuel AND assemblies within containment, or during E.2 Suspend movement of Immediately the movement of fuel fuel assemblies assemblies in the fuel within containment.

storage pool.

AND OR E.3 Suspend movement of Immediately One or more CREACUS fuel assemblies in trains inoperable due the fuel storage to an inoperable CRE pool.

boundary in MODE 5 or 6, or during movement of fuel assemblies within containment, or during the movement of fuel assemblies in the fuel storage pool.

(continued)

SAN ONOFRE--UNIT 2 3.7-25a Amendment No.

Fuel Storage Pool Water Level 3.7.16 3.7 PLANT SYSTEMS 3.7.16 Fuel Storage Pool Water Level LCO 3.7.16 The fuel storage pool water level shall be Ž 23 ft over the top of irradiated fuel assemblies seated in the storage racks.

APPLICABILITY: During movement of fuel assemblies in the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel storage pool A.1 ---------NOTE-------

water level not within LCO 3.0.3 is not limit, applicable.

Suspend movement of Immediately fuel assemblies in fuel storage pool.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.16.1 Verify the fuel storage pool water level is 7 days

> 23 ft above the top of irradiated fuel assemblies seated in the storage racks.

SAN ONOFRE--UNIT 2 3.7-29 Amendment No.

AC Sources- Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources-Shutdown LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:

a. One qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems Shutdown"; and

b. One diesel generator (DG) capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10.

APPLICABILITY: MODES 5 and 6, During movement of fuel assemblies within containment, During movement of fuel assemblies in the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite -------------NOTE-----------

circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized as a result of Condition A.

A.1 Declare affected Immediately required feature(s) with no offsite power available inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND (continued)

SAN ONOFRE--UNIT 2 3.8-17 Ampndmpnt No.

AC Sources- Shutdown 3.8.2 ACTIONS I CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.2 Suspend movement of Immediately fuel assemblies within containment.

AND A.2.3 Suspend movement of Immediately fuel assemblies in the fuel storage pool.

AND A.2.4 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND A.2.5 Initiate action to Immediately restore required offsite power circuit to OPERABLE status.

SAN ONOFRE--UNIT 2 3.8-18 Amendment No.

AC Sources- Shutdown 3.8.2 CONDITION R REQUIRED ACTION [COMPLETION TIME B. One required DG B.1 Suspend CORE Immediately inoperable. ALTERATIONS.

AND B.2 Suspend movement of Immediately fuel assemblies within containment.

AND B.3 Suspend movement of Immediately fuel assemblies in the fuel storage pool.

AND B.4 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND B.5 Initiate action to Immediately restore required DG to OPERABLE status.

SAN ONOFRE--UNIT 2 3.8-18a Amendment No.

DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources Shutdown LCO 3.8.5 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - Shutdown."

APPLICABILITY: MODES 5 and 6, During movement of fuel assemblies within containment, During movement of fuel assemblies in the fuel storage pool.

ACTIONS

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

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A.---------- NOTE --------- A.1 Restore battery 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months terminal voltage to Only applicable to greater than or equal 1800 amp-hour rated to the minimum batteries, established float voltage.

AND One or two required battery charger(s) on A.2 Verify battery float Once per 12 one train inoperable, current _ 1.50 amps. hours AND A.3.1 Restore required 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months battery charger(s) to OPERABLE status.

OR A.3.2.1 Provide ability to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ower the spare attery charger from a diesel-backed source.

AND A.3.2.2 Restore required 7 days battery charger(s) to OPERABLE status.

(continued)

SAN ONOFRE--UNIT 2 3.8-27 Amendment No.

DC Sources - Shutdown 3.8.5 CONDITION I REQUIRED ACTION I COMPLETION TIME D. One or more required D. 1 Declare affected Immediately DC electrical power required feature(s) subsystem(s) inoperable.

inoperable for reasons other than Condition A OR or B.

D.2.1 Suspend CORE Immediately ALTERATIONS.

AND D.2.2 Sus pend movement of Immediately fue] assemblies within containment.

AND D.2.3 Sus pend movement of Immediately fuel assemblies in the fuel storage pool.

AND D.2.4 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND D.2.5 Initiate action to Immediately restore required DC electrical power subsystem(s) to OPERABLE status.

SAN ONOFRE--UNIT 2 3.8-28 Amendment No.

Inverters- Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters -Shutdown LCO 3.8.8 Required inverters shall be OPERABLE to support the onsite Class 1E AC vital bus electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems- Shutdown."

APPLICABILITY: MODES 5 and 6, During movement of fuel assemblies within containment, During movement of fuel assemblies in the fuel storage pool ACTIONS CONDITION [ REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare affected Immediately inverters inoperable. required feature(s) inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately fuel assemblies within containment.

AND A.2.3 Sus pend movement of Immediately fuel assemblies in the fuel storage pool.

AND A.2.4 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND (continued)

.1. .1.

SAN ONOFRE--UNIT 2 3.8-36 Amendment No.

Inverters- Shutdown 3.8.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.5 Initiate action to Immediately restore required inverters to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct inverter voltage and 7 days alignment to required AC vital buses.

SAN ONOFRE--UNIT 2 3.8-37 Amendment No.

Distribution Systems - Shutdown 3.8.10 3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems - Shutdown LCO 3.8.10 The necessary portion of AC, DC, and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE APPLICABILITY: MODES 5 and 6.

During movement of fuel assemblies within containment, During movement of fuel assemblies in the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A. I Declare associated Immediately AC, DC, or AC vital supported required bus electrical power feature(s) inoperable.

distribution systems inoperable. OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately fuel assemblies within containment.

AND A.2.3 Sus pend movement of Immediately fuel assemblies in the fuel storage pool.

AND A.2.4 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND (continued)

SAN ONOFRE--UNIT 2 3.8-40 Amendment No.

Distribution Systems - Shutdown 3.8.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.5 Initiate actions to Immediately restore required AC, DC, and AC vital bus electrical power distribution system(s) to OPERABLE status.

AND A.2.6 Declare associated Immediately required shutdown cooling system(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.10.1 Verify correct breaker alignments and 7 days voltage to required AC, DC, and AC vital bus electrical power distribution systems.

SAN ONOFRE--UNIT 2 3.8-41 Amendment No.

Containment Penetrations 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Containment Penetrations LCO 3.9.3 The containment penetrations shall be in the following status:

a. The equipment hatch closed and held in place by four bolts;

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

The equipment hatch may be open if all of the following conditions are met:

1) The Containment Structure Equipment Hatch Shield Doors are capable of being closed within 30 minutes,

2) The plant is in Mode 6 with at least 23 feet of water above the reactor vessel flange,

3) A designated crew is available to close the Containment Structure Equipment Hatch Shield Doors,

4) Containment purge is in service, and

5) The reactor has been subcritical for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

b. One door in each air lock closed;

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

Both doors of the containment personnel airlock may be open provided:

a. one personnel airlock door is OPERABLE, and bl. the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel, or b2. defueled configuration with fuel in containment (i.e., fuel in refueling machine or upender).

c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either:

1. closed by a manual or automatic isolation valve, blind flange, or equivalent, or

2. capable of being closed by an OPERABLE Containment Purge System.

APPLICABILITY: During CORE ALTERATIONS, During movement of fuel assemblies within containment.

SAN ONOFRE--UNIT 2 3.9-4 Amendment No.

Containment Penetrations 3.9.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Suspend CORE Immediately containment ALTERATIONS.

penetrations not in required status. AND A.2 Sus pend movement of Immediately fuel assemblies within containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.3.1 Verify each required containment 7 days penetration is in the required status.

SR 3.9.3.2 Verify each required containment purge and 24 months exhaust valve actuates to the isolation position on an actual or simulated actuation signal.

SAN ONOFRE--UNIT 2 3.9-5 Amendment No.

Refueling Water Level 3.9.6 3.9 REFUELING OPERATIONS 3.9.6 Refueling Water Level LCO 3.9.6 Refueling water level shall be maintained Ž 23 ft above the top of reactor vessel flange.

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

Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs, coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling.

APPLICABILITY: During movement of fuel assemblies or CEAs within the reactor pressure vessel, During movement of fuel assemblies within containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Refueling water level A.1 Suspend CORE Immediately not within limit. ALTERATIONS.

AND A.2 Sus pend movement of Immediately fuel assemblies within containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 The refueling water level shall be 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months determined to be at least its minimum required depth.

SAN ONOFRE--UNIT 2 3.9-10 Amendment No.

Enclosure:

Evaluation of Proposed Change PCN 593 Attachment 5 (Proposed Technical Specification Pages, Unit 3

CPIS 3.3.8 3.3 INSTRUMENTATION 3.3.8 Containment Purge Isolation Signal (CPIS)

LCO 3.3.8 One CPIS channel shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, and 4,

,During CORE ALTERATIONS, During movement of fuel assemblies within containment.

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

Only required when the penetration is not isolated by appropriate closed and de-activated automatic valve(s),

closed manual valve(s), or blind flange(s).

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. CPIS Actuation Logic, A.1 Enter applicable Immediately or one or more Conditions and required channels of Re uired Actions for containment airborne affected valves of radiation monitors LCO 3.6.3, inoperable in MODES 1, "Containment 2, 3, and 4. Isolation Valves,"

made inoperable by CPIS instrumentation.

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 in AND MODES 1, 2, 3, or 4.

B.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (continued)

SAN ONOFRE--UNIT 3 3.3-35 Amendment No.

CPIS 3.3.8 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more required C.1 Enter applicable Immediately channels of conditions and containment airborne required actions of radiation monitors LCO 3.4.15, "RCS Leak inoperable in MODES 1, Detection."

2, 3, and 4.

NOTE----------

D. CPIS Manual Trip, - The provisions of LCO 3.0.3 Actuation Logic, or are not applicable.

one or more required channels of D.1 Place and maintain Immediately containment airborne containment purge radiation monitors supply and exhaust inoperable during CORE valves in closed

'ALTERATIONS or position.

movement of fuel assemblies within OR containment.

D.2.1 Suspend CORE Immediately ALTERATIONS.

AND D.2.2 Sus pend movement of Immediately fuel assemblies in containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.8.1 Perform a CHANNEL CHECK on required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months containment airborne radiation monitor channel.

(continued)

SAN ONOFRE--UNIT 3 3.3-36 Amendment No.

CRIS 3.3.9 3.3 INSTRUMENTATION 3.3.9 Control Room Isolation Signal (CRIS)

LCO 3.3.9 One CRIS channel shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, During movement of fuel assemblies within containment, During movement of fuel assemblies in the fuel storage pool.

ACTIONS

- NOTES------------------------

1. The provisions of LCO 3.0.3 are not applicable.

2. The provisions of LCO 3.0.4 are not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. CRIS Manual Trip, A.1 ---------NOTE-------

Actuation Logic, or Place Control Room one required channel Emergency Air Cleanup of control room System (CREACUS) in airborne radiation isolation mode if monitors inoperable in automatic transfer to MODES 1, 2, 3, or 4. isolation mode inoperable.

Place one CREACUS 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months train in emergency mode.

(continued)

SAN ONOFRE--UNIT 3 3.3-39 Amendment No.

CRIS 3.3.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. CRIS Manual Trip, B.I - --------

NOTE-------

Actuation Logic, or Place CREACUS in required control room isolation mode if airborne radiation automatic transfer to monitors inoperable in isolation mode MODE 5 or 6, or during inoperable.

movement of fuel assemblies within containment, or during Place one CREACUS Immediately the movement of fuel train in emergency assemblies within the mode.

fuel storage pool.

OR B.2.1 Suspend movement of Immediately fuel assemblies within containment.

AND B.2.2 Sus pend movement of Immediately fuel assemblies in the fuel storage pool.

AND B.2.3 ---------NOTE------- Immediately Limited plant control operations are allowed provided the changes are accounted for in the calculated SDM.

Suspend positive reactivity additions.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.9.1 Perform a CHANNEL CHECK on the required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months control room airborne radiation monitor channel.

(continued)

SAN ONOFRE--UNIT 3 3.3-40 Amendment No.

CREACUS 3.7.11 3.7 PLANT SYSTEMS 3.7.11 Control Room Emergency Air Cleanup System (CREACUS)

LCO 3.7.11 Two CREACUS trains shall be OPERABLE.

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

The control room envelope (CRE) boundary may be opened intermittently under administrative control.

APPLICABILITY: MODES 1, 2, 3, 4, 5, and 6, During movement of fuel assemblies within containment, During movement of fuel assemblies in the fuel storage pool.

ACTIONS ------------------------ NOTES--------------------------

1. The provisions of LCO 3.0.4 are not applicable when entering MODES 5, 6, or defueled configuration.

2. Each Unit shall enter applicable ACTIONS separately.

CONDITION REQUIRED ACTION COMPLETIONTIME A. One CREACUS train A.1 Restore CREACUS train 14 days inoperable for to OPERABLE status.

reasons other than Condition B..

B. One or more CREACUS B.1 Initiate action to Immediately trains inoperable due implement mitigating to inoperable CRE actions.

boundary in Modes 1, 2, 3, or 4. AND B.2 Verify mitigating 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months actions ensure CRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.

AND B.3 Restore CRE boundary 90 days to OPERABLE status.

(continued)

SAN ONOFRE--UNIT 3 3.7-24 Amendment No. I.

CREACUS 3.7.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A or AND B not met in MODE 1, 2, 3, or 4. C.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months D. Required Action and D.1 Place OPERABLE Immediately associated Completion CREACUS train in Time of Condition A not emergency radiation met in MODE 5 or 6, or protection mode.

during movement of fuel assemblies within OR containment, or during the movement of fuel D.2.1 Suspend CORE Immediately assemblies within the ALTERATIONS.

fuel storage pool.

AND D.2.2 Suspend movement of Immediately fuel assemblies within containment.

AND D.2.3 Suspend movement of Immediately fuel assemblies in the fuel storage pool.

SAN ONOFRE--UNIT 3 3.7-25 Amendment No.

CREACUS 3.7.11 ACTIONS E. Two CREACUS trains E.1 Suspend CORE Immediately inoperable in MODE 5 ALTERATIONS.

or 6, or during movement of fuel assemblies AND within containment, or during the movement of E.2 Suspend movement of Immediately fuel assemblies in the fuel assemblies fuel storage pool. within containment.

OR AND One or more CREACUS E.3 Suspend movement of Immediately trains inoperable due to fuel assemblies in inoperable CRE boundary the fuel storage in MODE 5 or 6, or pool.

during movement of fuel assemblies within containment, or during the movement of fuel assemblies in the fuel storage pool.

(continued)

SAN ONOFRE--UNIT 3 3.3-25a Amendment No.

Fuel Storage Pool Water Level 3.7.16 3.7 PLANT SYSTEMS 3.7.16 Fuel Storage Pool Water Level LCO 3.7.16 The fuel storage pool water level shall be Ž 23 ft over the top of irradiated fuel assemblies seated in the storage racks.

APPLICABILITY: During movement of fuel assemblies in the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Fuel storage pool A.1 ---------NOTE-------

water level not within LCO 3.0.3 is not limit, applicable.

Suspend movement of Immediately fuel assemblies in fuel storage pool.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.16.1 Verify the fuel storage pool water level is 7 days

> 23 ft above the top of irradiated fuel assemblies seated in the storage racks.

SAN ONOFRE--UNIT 3 3.7-29 Amendment No.

AC Sources- Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources-Shutdown LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:

a. One qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems Shutdown"; and

b. One diesel generator (DG) capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem(s) required by LCO 3.8.10.

APPLICABILITY: MODES 5 and 6, During movement of fuel assemblies within containment, During movement of fuel assemblies in the fuel storage pool.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite NOTE-----------

circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.10, with one required train de-energized as a result of Condition A.

A.1 Declare affected Immediately required feature(s) with no offsite power available inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND (continued)

SAN ONOFRE--UNIT 3 3.8-17 Amendment No.

AC Sources- Shutdown 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.2 Suspend movement of Immediately fuel assemblies within containment.

AND A.2.3 Suspend movement of Immediately fuel assemblies in the fuel storage pool.

AND A.2.4 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND A.2.5 Initiate action to Immediately restore required offsite power circuit to OPERABLE status.

SAN ONOFRE--UNIT 3 3.8-18 Amendment No.

AC Sources- Shutdown 3.8.2 CONDITION JREQUIRED ACTION j COMPLETION TIME B. One required DG B.1 Suspend CORE Immediately inoperable. ALTERATIONS.

AND B.2 Suspend movement of Immediately fuel assemblies within containment.

AND B.3 Suspend movement of Immediately fuel assemblies in the fuel storage pool.

AND B.4 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND B.5 Initiate action to Immediately restore required DG to OPERABLE status.

SAN ONOFRE--UNIT 3 3.8-19 Amendment No.

DC Sources - Shutdown 3.8.5 3.8 ELECTRICAL POWER SYSTEMS 3.8.5 DC Sources Shutdown LCO 3.8.5 The DC electrical power subsystem shall be OPERABLE to support the DC electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems - ShutdoWn."

APPLICABILITY: MODES 5 and 6, During movement of fuel assemblies within containment, During movement of fuel assemblies in the fuel storage pool.

ACTIONS

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

LCO 3.0.3 is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A.---------- NOTE --------- A.1 Restore battery 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months terminal voltage to Only applicable to greater than or equal 1800 amp-hour rated to the minimum batteries, established float voltage.

AND One or two required battery charger(s) on A.2 Verify battery float Once per 12 one train inoperable, current

1.50 amps. hours AND A.3.1 Restore required 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months battery charger(s) to OPERABLE status.

OR A.3.2.1 Provide ability to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ower the spare attery charger from a diesel-backed source.

AND A.3.2.2 Restore required 7 days battery charger(s) to OPERABLE status.

(continued)

SAN ONOFRE--UNIT 3 3.8-27 Amendment No.

DC Sources - Shutdown 3.8.5 CONDITION [ REQUIRED ACTION COMPLETION TIME D. One or more required D.1 Declare affected Immediately DC electrical power required feature(s) subsystem(s) inoperable.

inoperable for reasons other than Condition A OR or B.

D.2.1 Suspend CORE Immediately ALTERATIONS.

AND D.2.2 Suspend movement of Immediately fuel assemblies within containment.

AND D.2.3 Suspend movement of Immediately fuel assemblies in the fuel storage pool.

AND D.2.4 Suspend operations Immediately involving positive reactivit' additions that could result in loss of required SDM or boron concentration.

AND D.2.5 Initiate action to Immediately restore required DC electrical power subsystem(s) to OPERABLE status.

SAN ONOFRE--UNIT 3 3.8-28 Amendment No.

Inverters- Shutdown 3.8.8 3.8 ELECTRICAL POWER SYSTEMS 3.8.8 Inverters -Shutdown LCO 3.8.8 Required inverters shall be OPERABLE to support the onsite Class 1E AC vital bus electrical power distribution subsystem(s) required by LCO 3.8.10, "Distribution Systems- Shutdown."

APPLICABILITY: MODES 5 and 6, During movement of fuel assemblies within containment, During movement of fuel assemblies in the fuel storage pool.

ACTIONS CONDITION E REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare affected Immediately inverters inoperable. required feature(s) inoperable.

OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Sus pend moverment of Immediately fuel assembl ies within conta inment.

AND A.2.3 Suspend moverment of Immediately fuel assembl ies in the fuel stoirage pool.

AND A.2.4 Suspend oDer ations Immediately involving po*sitive reactivity a<dditions that could r esult in loss of requ ired SDM or boron concentratio n.

AND (continued)

SAN ONOFRE--UNIT 3 3.8-36 Amendment No.

Inverters- Shutdown 3.8.8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.5 Initiate action to Immediately restore required inverters to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.8.1 Verify correct inverter voltage and 7 days alignment to required AC vital buses.

SAN ONOFRE--UNIT 3 3.8-37 Amendment No.

Distribution Systems - Shutdown 3.8.10 3.8 ELECTRICAL POWER SYSTEMS 3.8.10 Distribution Systems - Shutdown LCO 3.8.10 The necessary portion of AC, DC, and AC vital bus electrical power distribution systems shall be OPERABLE to support equipment required to be OPERABLE.

APPLICABILITY: MODES 5 and 6.

During movement of fuel assemblies within containment, During movement of fuel assemblies in the fuel storage pool.

ACTIONS CONDITION R REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Declare associated Immediately AC, DC, or AC vital supported required bus electrical power feature(s) inoperable.

distribution systems inoperable. OR A.2.1 Suspend CORE Immediately ALTERATIONS.

AND A.2.2 Suspend movement of Immediately fuel assemblies within containment.

AND A.2.3 Suspend movement of Immediately fuel assemblies in the fuel storage pool.

AND A.2.4 Suspend operations Immediately involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND (continued)

SAN ONOFRE--UNIT 3 3.8-40 Amendment No.

Distribution Systems - Shutdown 3.8.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.5 Initiate actions to Immediately restore required AC, DC, and AC vital bus electrical power distribution system(s) to OPERABLE status.

AND A.2.6 Declare associated Immediately required shutdown cooling system(s) inoperable and not in operation.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.10.1 Verify correct breaker alignments and 7 days voltage to required AC, DC, and AC vital bus electrical power distribution systems.

SAN ONOFRE--UNIT 3 3.8-41 Amendment No.

Containment Penetrations 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Containment Penetrations LCO 3.9.3 The containment penetrations shall be in the following status:

a. The equipment hatch closed and held in place by four bolts;

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

The equipment hatch may be open if all of the following conditions are met:

1) The Containment Structure Equipment Hatch Shield Doors are capable of being closed within 30 minutes,

2) The plant is in Mode 6 with at least 23 feet of water above the reactor vessel flange,

3) A designated crew is available to close the Containment Structure Equipment Hatch Shield Doors,

4) Containment purge is in service, and

5) The reactor has been subcritical for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

b. One door in each air lock closed;

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

Both doors of the containment personnel airlock may be open. provided:

a. one personnel airlock door is OPERABLE, and bl. the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel, or b2. defueled configuration with fuel in containment (i.e., fuel in refueling machine or upender).

c. Each penetration providing direct access from the containment atmosphere to the outside atmosphere shall be either:

1. closed by a manual or automatic isolation valve, blind flange, or equivalent, or

2. capable of being closed by an OPERABLE Containment Purge System.

APPLICABILITY: During CORE ALTERATIONS, During movement of fuel assemblies within containment.

SAN ONOFRE--UNIT 3 3.9-4 Amendment No.

Containment Penetrations 3.9.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more A.1 Suspend CORE Immediately containment ALTERATIONS.

penetrations not in required status. AND A.2 Suspend movement of Immediately fuel assemblies within containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.3.1 Verify each required containment 7 days penetration is in the required status.

SR 3.9.3.2 Verify each required containment purge and 24 months exhaust valve actuates to the isolation position on an actual or simulated actuation signal.

SAN ONOFRE--UNIT 3 3.9-5 Amendment No.

Refueling Water Level 3.9.6 3.9 REFUELING OPERATIONS 3.9.6 Refueling Water Level LCO 3.9.6 Refueling water level shall be maintained Ž 23 ft above the top of reactor vessel flange.

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

Water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs, coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling.

APPLICABILITY: During movement of fuel assemblies or CEAs within the reactor pressure vessel, During movement of fuel assemblies within containment.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Refueling water level A.1 Suspend CORE Immediately not within limit. ALTERATIONS.

AND A.2 Sus pend movement of Immediately fuel assemblies within containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.6.1 The refueling water level shall be 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months determined to be at least its minimum required depth.

SAN ONOFRE--UNIT 3 3.9-10 Amendment No.

Enclosure:

Evaluation of Proposed Change PCN-593 Attachment 6 Proposed Technical Specifications Bases Markup Pages, Unit 2 (For Information Only)

CPIS B 3.3.8 B 3.3 INSTRUMENTATION B 3.3.8 Containment Purge Isolation Signal (CPIS)

BASES BACKGROUND This LCO encompasses the CPIS, which is a plant specific instrumentation channel that performs an actuation function required for plant protect-ion but is not otherwise included in LCO 3.3.6, "Engineered Safety Features Actuation System (ESFAS) Logic and Manual Trip," or LCO 3.3.7, "Diesel Generator (DG) -Undervoltage Start."

A CPIS radiation monitor will generate a train related containment purge isolation signal (CPIS) upon detection of high gaseous radiation in containment. This signal in turn initiates a close signal to all same train containment purge valves, both main and minipurge.

The CPIS, includes two independent, redundant logic subsystems, including actuation trains. Each train employs one gaseous sensor.

If either one of the corresponding sensors exceeds the bistable trip setpoint, the CPIS train will be actuated.

Each train actuates a separate series valve in the containment purge supply and return lines. Either train controls sufficient equipment to perform the isolation function. Minipurge valves are also isolated automatically on a Safety Injection Actuation Signal (SIAS) and Containment Isolation Actuation Signal (CIAS) in Modes 1-3.

Trip Setpoints The trip setpoint is set sufficiently high to prevent spurious alarms/trips yet sufficiently low to assure an alarm/tri.p should an inadvertent release occur. Compliance with this requirement provides suitable confirmation that.

the monitors are capab e of performing their intended function.

(continued)

SAN ONOFRE--UNIT 2 B 3.3-135 Amendment No. 127 05/28/97

CPIS B 3.3.8 BASES (continued)

APPLICABLE The containment airborne radiation monitors will generate an SAFETY ANALYSES isolation signal for the containment purge in the event of a LOCA. However, containment isolation is expected to occur on either a safety injection actuation system signal or a containment isolation actuation system signal prior to initiation on a CPIS signal on high radiation in containment. In addition, the cal culations show that, following a fuel handling accident in containment due to the response time of the containment airborne radiation monitors there will be some release of radioactivity to the environment prior to isolation of the purge by the CPIS.

In order to calculate the off-site-doses resulting from such a release, it was conservatively assumed that all of the airborne radioactivity resulting from a fuel handling accident in containment was released to the environment (i.e., the containment purge was not isolated following a fuel handling accident). The analysis showed that the 0-2 hour site boundary (exclusion area boundary [EAB]) thyroid dose and the 0-2 hour site boundary whole body (WB) dose would be below the Standard Review Plan (SRP) 15.7.4 limits of 75 rem thyroid and 6 rem WB (these SRP limits are based on 25 percent of the 10 CFR 100 limits).

General Design Criteria (GDC) 19 specifies that adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving r adiation exposures in excess of 5 rem WB, or its equivalent t o any part of the body, for the duration of the accident. SRP 6.4 defines the dose-equivalent to the thyroid as 30 rem. The analysis demonstrated that the dose va lues are below those specified in GDC 19 as delineated by SRP6.4.

(continued)

SAN ONOFRE--UNIT 2 B 3.3-136 Amendment No. 127 06/09/00 1

CPIS B 3.3.8 BASES (continued)

LCO LCO 3.3.8 requires one CPIS channel to be OPERABLE. The required channel consists of gaseous radiation monitors; Actuation Logic; and Manual Trip.

The Bases for the LCO on CPIS are discussed below for each Function:

a. Manual Trip The LCO on Manual Trip backs up the automatic trip and ensures operators have the capability to rapidly initiate the CPIS Function if any parameter is trending toward its set point. One manual channel of CPIS is reguired in MODES 1, 2, 3, and 4, since the CPIS'is redundant with the CIAS and SIAS. One manual channel of CPIS is required during CORE ALTERATIONS and movement of 4-rradia-ed fuel assemblies, since there are additional means of closing the containment purge valves in the event of a channel failure.

b. Gaseous Airborne Radiation The monitor detects in containment gaseous airborne radiation and provides an alarm and trip function upon reaching the setpoint value. The trip function opens a contact in the actuation logic. There are two monitors with input into redundant actuation trains.

c. Actuation Logic Actuation logic provides close signals to-both mini and main train related containment purge valves.

APPLICABILITY In MODES 1, 2, 3, and 4, the minipurge valves may be open.

In these MODES, it is necessary to ensure the valves will shut in the event of a primary leak in containment whenever any of the containment purge valves are open.

With the purge valves open during CORE *TERA uel as-em lee noi ir edsebis nd at*

fuel a~~eb; i ncnanment,v a e an* ng acci ent wou require CPIS on high radiation in containment.

(continued)

SAN ONOFRE--UNIT 2 B 3.3-137 Amendment No. 127 5/128o/9-7

CPIS B 3.3.8 BASES (continued)

APPLICABILITY The APPLICABILITY is modified by a Note, which states that (Continued) the CPIS Specification is only required when the penetration is not iso ated by appropriate closed and de-activated automatic valve(s), closed manual valve(s), or blind flange(s).

ACTIONS A CPIS channel is inoperable when it does not satisfy the OPERABILITY criteria for the channel's function. The most common cause of channel inoperability is outright failure or drift of the bistable or process module sufficient to exceed the tolerance allowed by the plant specific setpoint analysis. Typically, the drift is not large and would result in a delay of actuation rather than a total loss of function. This determination is generally made during the performance of a CHANNEL FUNCTIONAL TEST when the process instrument is set up for adjustment to bring it within specification. If the trip setpoint is not consistent with the value specified in the Surveillance Requirement SR 3.3.8.2, the channel must be declared inoperable immediately, and the appropriate Conditions must be entered.

In the event a channel's trip setpoint is found nonconservative with respect to the value specified in the Surveillance Requirement SR 3.3.8.2, or the sensor, instrument loop, signal processing electronics, or bistable is found inoperable, then all affected Functions provided by that channel are required to be declared inoperable and the LCO Condition entered for the particular protective function affected.

A.1 Condition A applies to the failure of CPIS, Actuation Logic, and gaseous radiation monitors. The Required Action is to enter the applicable Conditions and Required Actions for affected valves of LCO 3.6.3, "Containment Isolation Valves." The Completion Time accounts for the condition that the capability to isolate containment on valid containment high radiation or manual signals is degraded during power operation or shutdown modes.

(/

(conti nued)

SAN ONOFRE--UNIT 2 B 3.3-138 Amendment No. 127 05/28/97

CPIS B 3.3.8 BASES (continued)

ACTIONS B.1 and B.2 (continued)

Condition B applies when the Required Action and associated Completion Time of Condition A are not met in MODE 1, 2, 3, or 4. If Required Action A cannot be met within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

C.1 Condition C applies when one or more required channels of gaseous airborne radiation monitors are inoperable. The appropriate action is to enter LCO 3.4.15.

D.I. D.2.1. and D.2.2 Condition D applies to the same conditions as are described in Condition A; however, the applicability is during CORE ALTERATIONS or during the movement of irradate4 fuel assemblies within containment. Required Action D.1 is to place the containment purge and exhaust isolation valves in the closed position. The Required Action immediately performs the isolation function of the CPIS. Required Actions D.2.1 and D.2.2 may be performed in lieu of Required Action D.I. Required Action D.2.1 requires the suspension of CORE ALTERATIONS and Required Action D.2.2 requires suspension of movement of irradiated fuel in containment immediately. The Completion Time accounts for the fact that the automatic capability to isolate containment on valid containment high radiation signals is degraded during conditions in which a fuel handling accident is possible and CPIS provides the only automatic mitigation of radiation release.

SURVEILLANCE SR 3.3.8.1 REQUIREMENTS Performance of the CHANNEL CHECK once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ensures that a gross failure of instrumentation has not occurred on the required gaseous airborne radiation monitor channels used in the CPIS. A CHANNEL CHECK is a comparison of the (continued)

SAN ONOFRE--UNIT 2 B 3.3-139 Amendment No. 127 05/28/97

CPIS B 3.3.8 BASES (continued)

SURVEILLANCE SR 3.3.8.1 (continued)

REQUIREMENTS parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value.

Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the match criteria, it may be an indication that.the transmitter or the signal processing equipment has drifted outside its limit.

The Frequency, about once every shift, is based on operating experience that demonstrates the rarity of channel failure.

Thus, performance of the CHANNEL CHECK guarantees that undetected overt channel failure is limited to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Since the probability of two random failures in redundant channels in any 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months period is low, the CHANNEL CHECK minimizes the chance of loss of protective function due to failure of redundant channels. The CHANNEL CHECK supplements less formal, but more frequent, checks of channel OPERABILITY during normal operational use of the displays associated with the LCO required channels.

SR 3.3.8.2 A CHANNEL FUNCTIONAL TEST is performed on the required containment gaseous airborne radiation monitoring channel to ensure the entire channel will perform its intended function. Setpoints must be found as specified in SR 3.3.8.2 and left consistent with the assumptions of the setpoint analysis. The Frequency of 92 days is based on plant operating experience with regard to channel OPERABILITY and drift, which demonstrates that failure of more than one channel of a given Function in any 92 day Frequency is a rare event.

(continued)

SAN ONOFRE--UNIT 2 B 3.3-140 Amendment No. 127 05/28/97

CPIS B 3.3.8 BASES (continued)

SURVEILLANCE SR 3.3.8.3 REQUIREMENTS (Continued) Proper operation of the individual initiation relays is verified by actuating these relays during the CHANNEL FUNCTIONAL TEST of the Actuation Logic every 24 months.

This will actuate the Function, operating all associated equipment. Proper operation of the equipment actuated by each train is thus verified. The Frequency of 24 months is

based on plant operating experience with regard to channel OPERABILITY and. drift, which demonstrates that failure of more than one channel of a given Function during any 24 month interval is a rare event. A Note to the SR indicates that this Surveillance includes verification of operation for each initiation relay.

SR 3.3.8.4 CHANNEL CALIBRATION is a complete check of the instrument channel including the sensor. The Surveillance verifies that the channel responds to a measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drift between successive calibrations to ensure that the channel remains operational between successive surveillances. Measurement error determination, setpoint error determination, and calibration adjustment must be performed consistent with the plant specific setpoint analysis. The channel shall be left calibrated consistent with the assumptions of the current setpoint analysis.

The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

SR 3.3.8.5 This Surveillance ensures that the train actuation response times are less than or equal to the maximum times assumed in the analyses. The 24 month Frequency is based upon plant operating experience, which shows that random failures of instrumentation components causing serious response time degradation, but not channel failure, are infrequent occurrences. Testing of the final actuating devices, which make up the bulk of the response time, is included in the Surveillance.

(conti nued)

SAN ONOFRE--UNIT 2 B 3.3-141 Amendment No. 127 05/28/97

CPIS B 3.3.8 BASES (continued)

SURVEILLANCE SR 3.3.8.6 REQUIREMENTS (Continued) Every 24 months, a CHANNEL FUNCTIONAL TEST is performed on the CPIS Manual Trip channel.

This test verifies that the trip push buttons are capable of opening contacts in the Actuation Logic as designed, de-energizing the initiation relays and providing manual actuation of the Function. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillance when performed at a Frequency of once every 24 months.

REFERENCES 1. SONGS Units 2 and 3 UFSAR, Chapter 15.

2. 10 CFR 100.

SAN ONOFRE--UNIT-2 B 3.3-142 Amendment No. 127 05/28/97

CPIS B 3.3.8 BASES (continued)

THIS PAGE INTENTIONALLY LEFT BLANK SAN ONOFRE--UNIT 2 B 3.3-143 Amendment No. 127 05/28/97

CPIS B 3.3.8 BASES (continued)

THIS PAGE INTENTIONALLY LEFT BLANK SAN ONOFRE--UNIT 2 B 3.3-144 Amendment No. 127 05/28/97

CRIS B 3.3.9 B 3.3 INSTRUMENTATION B 3.3.9 Control Room Isolation Signal (CRIS)

BASES BACKGROUND This LCO encompasses CRIS actuation, which is a plant specific instrumentation channel that performs an actuation function required for plant protection but is not otherwise included in LCO 3.3.6, "Engineered Safety Features Actuation System (ESFAS) Logic and Manual Trip," or LCO 3.3.7, "Diesel Generator (DG) -Loss of Voltage Start (LOVS)." This is a non-Nuclear Steam Supply System ESFAS Function that, because of differences in purpose, design, and operating requirements, is not included in LCO 3.3.6 and LCO 3.3.7.

The CRIS terminates the normal supply of outside air to the control room and initiates actuation of the Control Room Emergency Air Cleanup System (CREACUS) to minimize operator radiation exposure. The CRIS includes two independent, redundant trains. Each train consists of a gaseous radiation monitor, manual trip function and actuation logic.

If the bistable monitoring either sensor indicates an unsafe condition, that train will be actuated (one-out-of-two logic). Each train related actuation signal operates the same train isolation equipment. Actuating either train will perform the intended function. Control room isolation also occurs on a Safety Injection Actuation Signal (SIAS) in MODES 1, 2, and 3.

Trip Setpoint Accidents crediting control room isolation from the CRIS radiation monitor(s) have been evaluated with the setpoint specified in the Surveillance Requirement. The resulting dose to the control room operators is within the IOCFR50 Appendix A General Design Criteria 19 limits.

(continued)

SAN ONOFRE--UNIT 2 B 3.3-145 Amendment No. 127 06/27/97

CRIS B 3.3.9 BASES (continued)

APPLICABLE The CRIS, in conjunction with the Control Room Emergency Air SAFETY ANALYSES Cleanup System (CREACUS), maintains the control room atmosphere within conditions suitable for prolonged occupancy throughout the duration of any one of the accidents discussed in Reference 1. The radiation exposure of control room personnel, through the duration of any one of the postulated accidents discussed in "Accident Analysis," SONGS Units 2 and 3 UFSAR, Chapter 15 (Ref. 1),

does not exceed the limits set by 10 CFR 50, Appendix A, GDC 19 (Ref. 3).

LCO LCO 3.3.9 requires one channel of CRIS to be OPERABLE. The required channel consists of Actuation Logic, Manual Trip, and gaseous radiation monitors. The specified value for the setpoint of the CRIS is listed in the SR.

The Bases for the LCO on the. CRIS are discussed below for each Function:

a. Manual Trip The LCO on Manual Trip backs up the automatic trips and ensures operators have the capability to rapidly initiate the CRIS Function if any parameter is trending toward its setpoint. One channel must be OPERABLE. This considers that the Manual Trip capability is a backup and that other means are available to actuate the redundant train if required, including manual SIAS.

b. Airborne Radiation One channel of Airborne Radiation detection in the required train is required to be OPERABLE to ensure the control room isolates on high gaseous concentration.

c. Actuation Lociic One train of Actuation Logic must be OPERABLE, since there are alternate means available to actuate the redundant train, including SIAS.

(continued)

SAN ONOFRE--UNIT 2 B 3.3-146 Amendment No. 127 12/01/08

CRIS B 3.3.9 BASES (continued)

APPLICABILITY The CRIS Functions must be OPERABLE in MODES 1, 2, 3, 4, 5 and 6, trn4 during movement of irradiated fuel assemblies in the control room operators.

ulasml nlds =rradiated fuel, non-C Thetr

irradi~ated :fuel, =the and dummy fuel assembly.

ACTIONS A CRIS channel is inoperable when it does not satisfy the OPERABILITY criteria for the channel's function. The most common cause of channel inoperability is outright failure or drift of the bistable or process module. Typically, the drift is not large and would result in a delay of actuation rather than a total loss of function. This determination is generally made during the performance of a CHANNEL FUNCTIONAL TEST when the process instrument is set up for adjustment to bring it within specification. if the trip setpoint is not within the specified value, the channel is inoperable and the appropriate Conditions must be entered.

The provisions of LCO's 3.0.3 and 3.0.4 are not applicable to this specification, as indicated by the two NOTES.

A.1, B.1, B.2.1, B.2.2, andtB2."*

Conditidns A and B have been modified by a Note, which specifies that CREACUS be placed manually in the isolation mode if the automatic transfer to the isolation mode is inoperable.

Conditions A and B are applicable to manual and automatic actuation of the CREACUS by CRIS. Condition A applies to the failure of the CRIS Manual Trip, Actuation Logic, and required gaseous radiation monitor channels in MODE 1, 2, 3, or 4. Entry into this Condition requires action to either restore the failed channel(s) or manually perform the CRIS safety function (Required Action A.1). The Completion Time of I hour is sufficient to complete the Required Actions and accounts for the fact that CRIS supplements control room isolation by other Functions in MODES 1,.2, 3, and 4.

(continued)

SAN ONOFRE--UNIT 2 B 3.3-1i47 Amendment No. 127 067/197

CRIS B 3.3.9 BASES (continued)

ACTIONS Condition B applies to the failure of CRIS Manual Trip, (continued) Actuation Logic, &td or required gaseous radiation monito__Z

'sr Rq rdAcin r mme lately taken to p ace one ERA 'BLECREACUS train in the emer enc e, or to suspend positive reactivity additionsan sus e movement of fuel assemblies iin.*

men an in T Vof J The Completion Time recognizes t e fact that the radiation signals are the only Functions available to initiate control room isolation in the event of a fuel handling accident.

Required Action B.2.2 is modified by a note to indicate that normal plant control operations that individually add limited positive reactivity (e.g., temperature or boron fluctuations associated with RCS inventory management or temperature control) are not precluded by this Action, provided they are accounted for in the calculated SDM.

SURVEILLANCE SR 3.3.9.1 REQUIREMENTS Performance of the CHANNEL CHECK once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value.

Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the match criteria, it may be an indication that the transmitter or the signal processing equipment has drifted outside its limit.

The Frequency, about once every shift, is based on operating experience that demonstrates the rarity of channel failure.

Thus, performance of the CHANNEL CHECK guarantees that undetected overt channel failure is limited to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Since the probability of two random failures in redundant channels in any 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months period is low, theCHANNEL CHECK minimizes the chance of loss of protective function due to failure of redundant channels. The CHANNEL CHECK (continued)

SAN ONOFRE--UNIT 2 B 3.3-148 Amendment No. +2-9,175 12/12/O 0

CRIS B 3.3.9 BASES (continued)

SURVEILLANCE SR 3.3.9.1 (continued)

REQUIREMENTS supplements less formal,' but more frequent, checks of channel OPERABILITY during normal operational use of the displays associated with the LCO required channels.

SR 3.3.9.2 A CHANNEL FUNCTIONAL TEST is performed on the required control room radiation monitoring channel to ensure the entire channel will perform its intended function. As found and as left setpoints are recorded.

The Frequency of 92 days is based on plant operating experience with regard to channel OPERABILITY and drift, which demonstrates that failure of more than one channel of a given Function in any 92 day .interva~l is a rare event.

SR 3.3.9.3 Proper operation of the individual initiation relays is verified by de-energizing these relays during the CHANNEL FUNCTIONAL TEST of the Actuation Logic every 18 months.

This will actuate the Function, operating all associated equipment. Proper operation of the equipment actuated by each train is thus verified.

The Frequency of 18 months is based on plant operating experience with regard to channel OPERABILITY, which demonstrates that failure of more than one channel of a given Function in any 18 month interval is a rare event.

A Note indicates this Surveillance includes verification of operation for each initiation relay.

SR 3.3.9.4 CHANNEL CALIBRATION is a complete check of the instrument channel including the sensor. The Surveillance verifies that the channel responds to a measured parameter within the necessary range and accuracy.

The Frequency of an 18 month calibration interval is based on experience with the magnitude of equipment drift in this period.

(conti nued)

SAN ONOFRE--UNIT 2 B 3.3-149 Amendment No. ,175 12/20/00 1

CRIS B 3.3.9 BASES (continued)

SURVEILLANCE SR 3.3.9.5 REQUIREMENTS (continued) Every 18 months, a CHANNEL FUNCTIONAL TEST is performed on the manual CRIS actuation circuitry.

This test verifies that the trip push buttons are capable of opening contacts in the Actuation Logic as designed, de-energizing the initiation relays and providing Manual Trip of the function. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillance when performed at a Frequency of once every 18 months.

SR 3.3.9.6 This Surveillance ensures that the train actuation response times are less than or equal to the maximum times assumed in the analyses. A time limit to isolate the control room is needed to ensure compliance with 10 CFR 50 Appendix A General Design Criterion 19. The 18 month frequency is based upon plant operating experience, which shows that random failures of instrumentation components causing serious response time degradation, but not channel failure, are infrequent occurrences. The response time is tested from the module input; i.e., the radiation detector response is not measured. Testing of the final actuating devices is included in the Surveillance. Response time testing acceptance criteria are included in Reference 4.

REFERENCES 1. SONGS Units 2 and 3 UFSAR, Chapter 15.

2. SCE Calculation A-92-NF-003.

3; 10 CFR 50, Appendix A, GDC 19.

4. Licensee Controlled Specification 3.3.100, "RPS/ESFAS Response Times."

SAN ONOFRE-7UNIT 2 B 3.3-150 Amendment No. 127 12/02/99 Re-issued on 08/20/01

CRIS B 3.3.9 BASES (continued)

THIS PAGE INTENTIONALLY BLANK SAN ONOFRE--UNIT 2 B 3.3-151 Amendment No. -I-2F-,175 <12/20/00 1

CREACUS B 3.7.11 B 3.7 PLANT SYSTEMS B 3.7.11 Control Room. Emergency Air Cleanup System (CREACUS)

BASES BACKGROUND The CREACUS provides a protected environment from which occupants can control the plant following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.

The CREACUS consists of two independent, redundant trains that recirculate and filter air in the control room envelope (CRE) and a CRE boundary that limits the inleakage of.

unfiltered air. Each CREACUS train consists of emergency air conditioning unit, emergency ventilation air supply unit, emergency isolation dampers, and cooling coils and two cabinet coolers per Unit. Each emergency air conditioning unit includes a prefilter, a high efficiency particulate air (HEPA) filter, an activated carbon adsorber section for removal of gaseous activity (principally iodines), and a fan. A second bank of HEPA filters follows the adsorber section to collect carbon fines. Each emergency ventilation air supply unit includes prefilter, HEPA filter, carbon adsorber and fan. Ductwork, motor-operated dampers, doors, barriers, and instrumentation also form part of the system.

Air and motor-operated dampers are provided for air volume control and system isolation purposes.

The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions.

This area encompasses the control room, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CRE is protected during normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE.

The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analyses of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.

(continued)

SAN ONOFRE--UNIT 2 B 3.7-56 Amendment No. 127 12/12/07 1

CREACUS B 3.7.11 BASES (continued)

BACKGROUND Upon receipt of the actuating signal, normal air supply to (continued) the CRE is isolated, and the stream of ventilation air is recirculated through the system's filter trains. The prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers. Continuous operation of each train for at least 15 minutes per month verifies proper system operability.

There are two CREACUS operational modes. Emergency mode is an operational mode when the control room is isolated to protect operational personnel from radioactive exposure through the duration of any one of the postulated limiting faults discussed in Chapter 15 UFSAR (Ref. 2). Isolation mode is an. operational mode when the CRE is isolated to protect operational personnel from toxic gasses and smoke.

Actuation ýof the CREACUS places the system into either of two separate states of operation, depending on the initiation signal. Actuation of the system to either the emergency mode or isolation mode of CREACUS operation closes the unfiltered-outside-air intake and unfiltered exhaust dampers, and aligns the system for recirculation of air within the CRE through the redundant trains of HEPA and charcoal filters.

The emergency mode also initiates pressurization of the CRE.

Outside air is added to the air being recirculated from the CRE. Pressurization of the CRE minimizes infiltration of unfiltered air through the CRE boundary from all the surrounding areas adjacent to the CRE boundary.

The CRE supply and the outside air supply of the normal control room HVAC are monitored by radiation and toxic-gas detectors respectively. One detector output above the setpoint will cause actuation of the emergency mode or isolation mode as required. The actions of the isolation mode are more restrictive, and will override the actions of the emergency mode of operation. However, toxic gas and radiation events are not considered to occur concurrently.

(continued)

SAN ONOFRE--UNIT 2 B 3.7-57 Amendment No. 127 12/12/07

CREACUS B 3.7.11 BASES (continued)

BACKGROUND Redundant recirculation trains provide the required (continued) filtration should an excessive pressure drop develop across the other filter train. Normally-open isolation dampers are arranged in series pairs so that one damper's failure to shut will not result in a breach of isolation. The CREACUS is designed in accordance with SeismicCategory I requirements.

The CREACUS is designed to maintain a habitable environment in theCRE for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding a 5-rem total effective dose equivalent (TEDE).

APPLICABLE The CREACUS components are arranged in redundant, safety SAFETY ANALYSES related ventilation trains. The location of components and ducting within the CRE ensures an adequate supply of filtered air to all areas requiring access.

The CREACUS provides airborne radiological protection for the CRE occupants, as demonstrated by the CRE occupant dose analyses for the most limiting design basis loss of coolant-accident fission product release presented in the UFSAR, Chapter 15 (Ref. 2).

Dose calculations, as specified in Unit 2/3 UFSAR Chapter 15 (Reference 2), only take credit for the HEPA filters and charcoal adsorbers of the emergency recirculation air conditioning unit. The emergency ventilation supply unit is designed to contribute to the pressurization of the control room to minimize unfiltered inleakage as indicated in Unit 2/3 UFSAR.

(continued)

SAN ONOFRE--UNIT 2 B 3.7-58 Amendment No. 127 12/12/07 I

CREACUS B 3.7.11 BASES (continued)

APPLICABLE The CREACUS provides protection from smoke and hazardous SAFETY ANALYSES chemicals to the CRE occupants. The analysis of hazardous (continued) chemical releases demonstrates that the toxicity limits are not exceeded in the CRE following a hazardous chemical release (Ref. 3). The evaluation of a smoke challenge demonstrates that it will not result in the inability of the CRE occupants to control the reactor either from the control room or from the remote shutdown panels (Ref. 4).

The worst case single active failure of a component of the CREACUS, assuming a loss of offsite power, does not impair the ability of the system to perform its design function.

The CREACUS satisfies Criterion 3 of the NRC Policy Statement.

LCO Two independent and redundant trains of the CREACUS are required to be OPERABLE to ensure that at least one is available if a single active failure disables the other train. Total system failure, such as from a loss of both ventilation trains or from an inoperable CRE boundary, could result in exceeding a dose of 5 rem TEDE to the CRE occupants in the event of a large radioactive release.

Each CREACUS train is c onsidered OPERABLE when the individual components necessary to limit CRE occupant exposure are OPERABLE. A CREACUS train is considered OPERABLE when the assoc iated:

a. Fan is OPERABLE;

b. HEPA filters and charcoal adsorber are not excessively restricting flow, and are capable of performing their filtration functions; and (continued)

SAN ONOFRE--UNIT 2 B 3.7-59 Amendment No. 128 12/12/07

CREACUS B 3.7.11 BASES (continued)

LCO c. Ductwork, valves, and dampers are OPERABLE, and air (continued) circulation can be maintained. If an Emergency Isolation Damper is stuck open, the associated train of CREACUS may still be considered OPERABLE if the redundant damper in series with the inoperable damper is closed with power removed.

In order for the CREACUS trains to be considered OPERABLE, the CRE boundary must be maintained such that CRE occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and smoke.

The LCO is modified by a Note allowing the CRE boundary to be opened intermittently under administrative controls.

This note only applies to openings in the CRE boundary that can be rapidly restored to the design condition, such.as doors, hatches, floor plugs, and access panels. For entry and exit through doors the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the'CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE isolation is indicated.

(continued)

SAN ONOFRE--UNIT 2 B 3.7-60 Amendment No. 127 12/12/07 [

CREACUS B 3.7.11 BASES (continued)

APPLICABILITY In MODES 1, 2, 3, 4, 5, and 6, &tn during movement of irradia-ted fuel assemb]ies in containment, an during movement-of fuel assemblies in t' el storage ool the CREACUS must be OPERABLE to ensure that the CRE will remain habitable during and following a DBA.

non- /

Th em ulassembly includes irradiated fuel, iadiated fuel, and the dummy fuel assembly.

In MODES 5 and 6, the CREACUS is required to cope with the release from a rupture of a waste gas tank.

During movement of iia-d-ated fuel assemblies, the CREACUS must be OPERABLE to cope with the release from a fuel handling accident involving handling irradiated fuel.

ACTIONS ACTION statements are modified by two NOTES. NOTE I says:

"The provisions of LCO 3.0.4 are not applicable when entering MODES 5, 6, or defueled configuration."

Specification 3.0.4 establishes that entry into an operational mode or other specified condition shall not be made unless the conditions of the LCO are met.

Applicability statements "During movement of iradid fuel ass embli es (i-nccon ta-in ment ,-and during movement of fu .

assemb ie in the fu storage pool" ensures the OPERABILITY of both CREACUS trains prior to the start~of movement of irraidi-ated. fuel assemblies.

NOTE 2 says: "Each Unit shall enter applicable ACTIONS separately." CREACUS is a shared system between Unit 2 and Unit 3. LCO doesn't address the operational situation when the Units are in different operational MODES. Without this NOTE it may not be clear what ACTIONS should be taken.

(continued)

SAN ONOFRE--UNIT 2 B 3.7-61 Amendment No. 128 12/12/07

CREACUS B 3.7.11 BASES (continued)

ACTIONS A.1 (continued)

With one CREACUS train inoperable, for reasons other than an inoperable CRE boundary, action must be taken to restore OPERABLE status within 14 days. The 14 day AOT is based on a probabilistic risk assessment that does-not require administrative controls to be implemented when a CREACUS train is taken out of service. In this Condition, the remaining OPERABLE CREACUS train is adequate to perform the CRE occupant protection function.

However, the overall reliability is reduced because a failure in the OPERABLE CREACUS train could result in loss of CREACUS function. The 14 day Completion Time is based on the low probability of a DBA occurring during this time period, and the ability of the remaining train to provide the required capability.

B.I. B.2 and B.3 If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem TEDE), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 90 days.

(continued)

SAN ONOFRE--UNIT 2 B 3.7-62 Amendment No. 128 12/12/07

CREACUS B 3.7.11 BASES (continued)

ACTIONS During the period that the CRE boundary is considered (continued) inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e., actions that are taken to offset the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

C.1 and C.2 In MODES 1, 2, 3, or 4, if the inoperable CREACUS or the CRE boundary cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes the accident risk. To achieve this status, 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 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

(continued)

SAN ONDFRE--UNIT 2 B 3.7-63 Amendment No. 208 12/12/07 1

CREACUS B 3.7.11 BASES (continued)

ACTIONS D.1, D.2.1, D.2.2 an 0.2.3 (continued)

In MODE 5 or 6, or during movement of irrad+a+ed fuel Action Ae1 cannot be comp ete required Completion Time, the OPERABLE CREACUS train must be immediately placed in the emergency mode of operation. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will-occur, and that any active failure will be readily detected."

An alternative to Required Action D.I is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel assemblies to a safe position.

E.I E.2 and.3 When in MODE 5 or 6, or during movement of irradiated fuel inopera le or wi one 6r mor S trains inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that could result in a release of radioactivity that might enter the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

F.1 If both CREACUS trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable CRE boundary (i.e.,

Condition B), the CREACUS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

(continued)

SAN ONOFRE--UNIT 2 B 3.7-64 Amendment No.208 12-i+/-2/O47

CREACUS B 3.7.11 BASES (continued)

SURVEILLANCE SR 3.7.11.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. Since the environment and normal operating conditions on this system are not severe, testing each train once every month provides an adequate check on this system, Cumulative operation of the system for at least 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months over a 31 day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filtes. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months time frame is based on a conservative engineering evaluation which calculated the time required to evaporate the moisture contained in the air trapped inside the CREACUS duct upstream of charcoal beds. The 31.day Frequency is based on the known reliability of the equipment, and the two train redundancy available.

SR 3.7.11.2 This SR verifies that the required CREACUS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CREACUS filter tests are based on Regulatory Guide 1.52 (Ref. 5). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of theactivated charcoal (general use and following specific operations). Specific test Frequencies and additional information are discussed in detail in the VFTP.

The filtration efficiency only apply to the emergency recirculation air conditioning units E418 and E419.

Therefore, testing for filtration efficiency is not required for the emergency ventilation supply units A206 and A207.

However, the specified air flow from the emergency ventilation units is required during the filtration efficiency testing of the emergency recirculation air conditioning units. Also, the air flow requirements which are specified in the VFTP apply to the emergency ventilation and emergency air conditioning units.

(continued)

SAN ONOFRE--UNIT 2 B 3.7-65 Amendment No. 208 12/12/07

CREACUS B 3.7.11 BASES (continued)

SURVEILLANCE SR 3.7.11.3 REQUIREMENTS (continued) This SR verifies that each CREACUS train starts and operates on an acutual or simulated actuation signal. The Frequency of 24 months is based on industry operating experience and is consistent with the typical refueling cycle.

SR 3.7.11.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences i.s no more than 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke.

This SR verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 6) which endorses, with exceptions, NEI 99-03, Section (continued)

SAN ONOFRE--UNIT 2 B 3.7-66 Amendment No. 208 12/12/07

CREACUS B 3.7.11 BASES (continued)

SURVEILLANCE SR 3.7.11.4 REQUIREMENTS (continued) 8.4 and Appendix F (Ref. 7). These compensatory measures may also be used as mitigating actions as required by Required Action B.2. Temporary analytical methods may also

be used as compensatory measures to restore OPERABILITY (Ref. 8). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

REFERENCES 1. UFSAR, Section 9.4.

2. UFSAR, Chapter 15.

3. UFSAR, Section 6.4.

4. UFSAR, Section 9.5.

5. Regulatory Guide 1.52 (Rev. 2).

6. Regulatory Guide 1.196.

7. NEI 99-03, "Control Room Habitability Assessment,"

June 2001.

8. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability." (ADAMS Accession No. ML040300694).

(continued)

SAN ONOFRE--UNIT 2 B 3.7-67 Amendment No. 208 12/12/07 1

Fuel Storage Pool Water Level B 3.7.16 B 3.7 PLANT SYSTEMS B 3.7.16 Fuel Storage Pool Water Level BASES BACKGROUND The minimum water level in the fuel storage pool meets the assumptions of iodine decontamination factors following a fuel handling accident. The specified water level shields and minimizes the general area dose when the storage racks are filled to their maximum capacity. The water also provides shielding during the movement of spent fuel.

A general description of the fuel storage pool design is given in the UFSAR, Section 9.1.2, Reference 1, and the Spent Fuel Pool Cooling and Cleanup System is given in the UFSAR, Section 9.1.3 (Ref. 2). The assumptions of the fuel handling accident are given in the UFSAR, Section 15.7.3.4 and 15.7.3.6 (Ref. 3 and Ref. 6).

APPLICABLE The minimum water level in the fuel storage pool meets the SAFETY ANALYSES assumptions of the fuel handling accident described in Regulatory Guide 1.25 (Ref. 4). The resultant 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thyroid dose to a person at the exclusion area boundary is a small fraction of the 10 CFR 100 (Ref. 5) limits.

According to Reference 4, there is 23 ft of water between the top of the damaged fuel bundle and the fuel pool surface for a fuel handling accident. With this 23 ft of water, the assumptions of Reference 4 can be used directly. In practice, this LCO preserves this assumption for the bulk of the fuel in the storage racks. In the case of a single bundle, dropped and lying horizontally on top of the spent fuel racks, there would be < 23 ft of water above the top of the bundle.

However, when the potential of a dropped fuel assembly exists (which is when fuel is being moved) a water level is maintained that would ensure that there would be >23 feet above the fuel assembly laying on top of the racks. This increased water level is required by LCO 3.9.6 when the fuel storage pool is connected to the refueling cavity and by station procedures whenever fuel is being moved.

(continued)

SAN ONOFRE--UNIT 2 B 3.7-68 Amendment No. 127 10/13/98 Reissued 06/23/99

Fuel Storage Pool Water Level B 3.7.16 BASES (continued)

APPLICABLE The fuel storage pool water level satisfies Criterion 3 of SAFETY ANALYSES the NRC Policy Statement.

(continued)

LCO The specified water level preserves the assumptions of the fuel handling accident analysis (Ref. 3). As such, it is the minimum required for fuel storage and movement within the fuel storage pool.

APPLICABILITY This LCO applies during movement of i,,adate fuel oQ-I radiated fue a CZhe dummy fue assembl in t *ulsoaepo since the potential for a release of fission products exists.

ACTIONS AA.1 Required Action. A.1 is modified by a Note indicating that LCO 3.0.3 does not apply.

When the initial conditions for an accident cannot be met, steps should be taken to preclude the accident from occurring. When the fuel storage pool water level is lower than the required level, the movement of irradiated fuel assemblies in the fuel storage pool is immediately suspended. This effectively precludes a spent fuel. handling accident from occurring. This does not preclude moving a fuel assembly to a safe position.

If moving irrad iated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODES 1, 2, 3, and 4, the fuel movement is independent of reactor operations.

Therefore, in either case, inability to suspend movement of irradiated fuel assemblies is not sufficient reason to require a reactor shutdown.

(continued)

SAN ONOFRE--UNIT 2 B 3.7-69 Amendment No. 127 10/H/198

Fuel Storage Pool Water Level B 3.7.16 BASES (continued)

SURVEILLANCE SR 3.7.16.1 REQUIREMENTS This SR verifies sufficient fuel storage pool water is available in the event of a fuel handling accident. The water level in the fuel storage pool must be checked periodically. The 7 day Frequency is appropriate because the volume in the pool is normally stable. Water level changes are controlled by unit procedures and are acceptable, based on operating experience.

During refueling operations, the level in the fuel storage pool is at equilibrium with that of the refueling canal, and the level in the refueling canal is checked daily in accordance with LCO 3.9.6, "Refueling Water Level."

REFERENCES 1. UFSAR, Section 9.1.2.

2. UFSAR, Section 9.1.3.

3. UFSAR, Section 15.7.3.4.

4. Regulatory Guide 1.25

5. 10 CFR 100.11.

6. UFSAR, Section 15.7.3.6 SAN ONOFRE--UNIT 2 B 3.7-70 Amendment No. 127 10/13/98

AC Sources- Shutdown B 3.8.2 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.2 AC Sources-Shutdown BASES BACKGROUND A description of the AC sources is provided in the Bases for LCO 3.8.1, "AC Sources-Operating."

APPLICABLE The OPERABILITY of the minimum AC sources during MODES 5 SAFETY ANALYSES and 6 ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods;

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

c. Adequate AC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident.

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required. The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1,.2, 3, and 4 have no specific analyses in MODES 5 and 6. Worst case bounding events are deemed not credible in MODES 5 and 6 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.

During MODES 1, 2, 3, and 4, various deviations from the analysis assumptions and design requirements are allowed within the Required Actions. This allowance is in recognition that certain testing and maintenance activities (continued)

SAN ONOFRE--UNIT 2 IB 3.8-30 Amendment No. 127

AC Sources - Shutdown B 3.8.2 BASES (continued)

APPLICABLE must be conducted provided an acceptable level of risk is SAFETY ANALYSES not exceeded. During MODES 5 and 6, performance of a (continued) significant number of required testing and maintenance activities is also required. In MODES 5 and 6, the activities are generally planned and administratively controlled. Relaxations from MODE 1, 2, 3, and 4 LCO requirements are acceptable during shutdown modes based on:

a.. The fact that time in an outage is limited. This is a risk prudent goal as well as a utility economic consideration.

b. Requiring appropriate compensatory measures for certain conditions. These may include administrative controls, reliance on systems that do not necessarily meet typical design requirements applied to systems

credited in operating MODE analyses, or both.

c. Prudent utility consideration of the risk associated with multiple activities that could affect multiple systems.

d. Maintaining, to the extent practical, the ability to perform required functions (even if not meeting MODE 1, 2, 3, and 4 OPERABILITY requirements) with systems assumed to function during an event.

In the event of an accident during shutdown, this LCO ensures the capability to support systems necessary to avoid immediate difficulty, assuming either a loss of all offsite power or a loss of all onsite diesel generator (DG) power.

The AC sources satisfy Criterion 3 of the NRC Policy Statement.

LCO One offsite circuit capable of supplying the onsite Class 1E power distribution subsystem(s) of LCO 3.8.10, "Distribution Systems-Shutdown," ensures that all required loads are powered from offsite power. An OPERABLE DG, associated with a distribution system train required to be OPERABLE by LCO 3.8.10, ensures a diverse power source is available to provide electrical power support, assuming a loss of the offsite circuit. Together, OPERABILITY of the required offsite circuit and DG ensures the availability of (continued)

SAN ONOFRE--UNIT 2 B 3.8-31 Amendment No. 127

AC Sources - Shutdown B 3.8.2 BASES (continued)

LCO sufficient AC sources to operate the unit in a safe manner (continued) and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

The qualified offsite circuit must be capable of maintaining rated frequency and voltage, andaccepting required loads during an accident, while connected to the Engineered Safety Feature (ESF) bus(es). Qualified offsite circuits are those that are described in the UFSAR and are part of the licensing basis for the unit.

One source of offsite power (Offsite circuit #1) for each unit is normally provided through Reserve Auxiliary Transformers XR1 and XR2 for the specific unit. XR1 feeds one 4.16 KV ESF bus (Train A) A04 and XR2 feeds the other 4.16 KV ESF bus (.Train B) A06 of the onsite Class 1E AC distribution system for each unit. The second source of offsite power (Offsite circuit #2) is provided by the other unit's Reserve Auxiliary Transformers XR1 and XR2 through the train oriented 4.16 KV ESF bus crossties between the two units. In addition, an alternate offsite source of power for each unit would be, with the unit's main generator isophase bus links removed, each unit's Auxiliary Transformer XU1.

The DG must be capable of starting, accelerating to rated speed and voltage, connecting to its respective ESF bus on detection of bus undervoltage, and accepting required loads.

This sequence must be accomplished within 10 seconds. The DG must be capable of accepting required loads within the assumed loading sequence intervals, and must continue to operate until offsite power can be restored to the ESF buses. These capabilities are required to be met from a variety of initial conditions such as DG in standby with the engine hot, DG in standby at ambient conditions, and DG.

operating in a parallel test mode.

Proper sequencing of loads, including tripping of nonessential loads, is a required function for DG OPERABILITY. Load sequencing is accomplished through the programmed time load sequence interval utilizing individual timing relays for each load in lieu of a single "automatic load sequencer."

(continued)

SAN ONOFRE--UNIT 2 B 3.8-32 Amendment No. 127

AC Sources- Shutdown B 3.8.2 BASES (continued)

LCO It is acceptable for trains to be cross tied during shutdown (continued) conditions, allowing a single offsite power circuit to supply all required trains.

APPLICABILITY The AC sources required to be OPERABLE in MODES 5 and 6, t-nA

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in the core;

b. Systems needed to mitigate a fuel handling accident are avai'lable;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The AC power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.1.

nlds i rr adiated fuell, nnon--

C ~~The emfeasml iradaedfeadthe dummy fuel assembly.

ACTIONS A.__

An offsite circuit would be considered inoperable if it were not available to the required ESF train. Although one train is required by LCO 3.8.10 the remaining train with offsite power available may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and/or fuel movement. By the allowance of the option to declare inoperable the required features associated with the inoperable offsite circuit, appropriate restrictions will be implemented in accordance with the affected required features LCO's ACTIONS.

(continued)

SAN ONOFRE--UNIT 2 B 3.8-33 Amendment No. 127

AC Sources- Shutdown B 3.8.2 BASES (continued)

ACTIONS .1.A.2.2, A.2.3, A.2.4 1. 9' B.1, B.2, B.3, B.4, and (continued)

With the offsite circuit not available to the required train (Condition A), the option exists to declare all required features inoperable. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made. With the required DG inoperable (Condition B), the minimum required diversity of AC power sources is not available. It I therefore, required to suspend CORE ALTERATIONS, s spe movement of iradiated fuel assemblies wi containment, 1,p as em

ois in e e V a r ivity a itions that could result in loss of required SDM (Mode 5) or boron concentration (Mode 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation' Introduction of coolant inventory must be from sources that have a boron concentration greater than what would be required in the RCS for minimum SDM or refueling .boro.n concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition.

These actions minimize the probability or the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the unit safety systems.

Notwithstanding performance of the conservative Required Actions, the unit is still without sufficient AC power sources to operate in a safe manner. Therefore, action must be initiated to restore the minimum required AC power sources and continue until the LCO requirements are restored.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be without sufficient power.

(continued)

SAN ONOFRE--UNIT 2 B 3.8-34 Amendment No. 4-2-7,175

AC Sources- Shutdown B 3.8.2 BASES (continued)

ACTIONS B..5.1. A.2.2. A.2.3, A.2.4,ŽA.2.5 B.1, B.2, B.3, B.4, and

t'inued)

Pursuant to LCO 3.0.6, the Distribution System's (LCO 3.8.10) ACTIONS are not entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A are modified by a Note to indicate that when Condition A is entered with no AC power to one ESF bus, the ACTIONS for LCO 3.8.10 must be immediately entered. This Note allows Condition A to provide requirements for the loss of the offsite circuit, whether or not a train is de-energized. LCO 3.8.10 provides, the appropriate restrictions for the situation involving a de-energized train.

SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, 3, and 4. SR 3.8.1.17 is not required to be met because the required OPERABLE DG is not required to undergo periods of being synchronized to the offsite circuit. SR 3.8.1.20 is excepted because starting independence is not required with DG(s) that are not required to be OPERABLE.

This SR is modified by a Note. The reason for the.Note is to preclude requiring the OPERABLE DG from being paralleled with the offsite power network or otherwise rendered inoperable. With limited AC Sources available, a single event could unnecessarily compromise both the required circuit and the DG. The SRs listed in the Note are not required to be performed for the OPERABLE AC sources during Modes 5 and 6, "4 during movement of ird-ad ed fuel souc e s eumeto able to meet these surveillances. If it is discovered (through analysis or unplanned events, for example) that the required AC sources could not meet these surveillances, then the equipment must be considered inoperable. Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

REFERENCES 1. UFSAR, Chapter 15.

SAN ONOFRE--UNIT 2 B 3 .8-35 Amendment No. 4-I-2-,175

DC Sources- Shutdown B 3.8.5 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.5 DC Sources -Shutdown BAS ES BACKGROUND A description of the DC sources is provided in the Bases for LCO 3.8.4, "DC Sources - Operating." When TS 3.8.5 applies, there are two exceptions to what is described in the Bases for LCO 3.8.4:

1. One or both train(s) of the DC subsystem buses may be cross-tied to an 1800 amp-hour rated battery. This alignment allows both subsystems to remain OPERABLE. There is no time limit to the duration DC subsystem buses may be cross-tied with the unit shutdown.

2. With same train DC buses cross connected, an OPERABLE charger or chargers with a combined rated capacity greater than or equal to 300 Amps is required. A "required battery charger" is one of the following:

0 the "dedicated charger" aligned to its respective DC bus 0 the "swing battery charger" aligned to the respective DC bus 6 one "dedicated charger" aligned to cross-tied DC buses, or 0 the "swing battery charger" aligned to cross-tied DC buses; Note: It is acceptable to have the swing charger and one dedicated charger aligned to cross-connected buses.

APPLICABLE The initial conditions of Design Basis Accident (DBA) and SAFETY ANALYSES transient analyses in the UFSAR, Chapter 6 (Ref. 1) and Chapter 15 (Ref. 2), assume that Engineered Safety Feature (ESF) systems are OPERABLE. The DC electrical power system provides normal and- emergency DC electrical power for the DGs, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum DC electrical power sources dur M and 6, -&m4 during movement of 1fuel

a. The unit can be maintained in the shutdown or refueling condition for extended periods; (continued)

SAN ONOFRE--UNIT 2 B 3.8-56 Amendment No. 127 &/137/On

DC Sources - Shutdown B 3.8.5 BASES APPLICABLE b. Sufficient instrumentation and control capability is SAFETY ANALYSES available for monitoring and maintaining the unit (continued) status; and

c. Adequate DC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident.

The DC sources satisfy Criterion 3 of the NRC Policy Statement.

LCO Each DC electrical power subsystem, consisting of one battery (cross connection allowed), the required battery charger, and the corresponding control equipment and interconnecting cabling supplying power to the associated bus, is required to be OPERABLE to support distribution systems required OPERABLE by.LCO 3.8.10, "Distribution Systems - Shutdown." This ensures the availability of sufficient DC electrical power sources to-maintain the unit in a safe shutdown condition and to mitigate the consequences of postulated events during shutdown (e.g.,

fuel handling accidents).

APPLICABILITY The DC electrical power sources required to* be OPERABLE f in MODES 5.and 6 zm drng movement of "

a. Required features to mitigate a fuel handling accident are available;

b. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

c. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The DC electrical power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.4.

The t er asul ncludes iradia ted fuel,-non---

raitdu n he dumm fuel seby ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irrdiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, .the ACTIONS have been modified by a NOTE stating that LCO 3.0.3 is not applicable. If moving +/-rad-a fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify (continued)

SAN ONOFRE--UNIT 2 B 3.8-57 Amendment No. 127 03/13/09

DC Sources- Shutdown B 3.8.5 BASES ACTIONS any action. If moving irradiated fuel assemblies while in (continued) MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3 or 4 would requirethe unit to be shutdown unnecessarily.

Conditions A and B represent one train with one or two required battery chargers or associated control equipment or cabling inoperable (e.g., the battery voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restoring the required charger(s) to OPERABLE status in a reasonable time period.

A.I. A.2, and A.3 (A.3.1 or A.3.2.1 and A.3.2.2)

Condition A is modified by a NOTE identifying that it is only applicable to 1800 amp-hour rated batteries.

Required Action A.1 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage (? 129.0 V) within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This time provides for returning the inoperable charger to OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring the battery terminal voltage to greater than or equal to minimum established float voltage provides good assurance that, within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the battery will be restored to its fully charged condition (Required Action A.2) from any discharge that might have occurred due to the charger inoperability.

A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on theexponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus, there is good assurance of fully recharging the battery within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , avoiding a shutdown of refueling activities.

If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and the charger is not operating in the current limiting mode, a faulty charger is indicated. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during the recovery period following a battery discharge event that the DC system is designed for.

(continued)

SAN ONOFRE--UNIT 2 B 3.8-58 Amendment No. 127 e3/13/89

DC Sources- Shutdown B 3.8.5 BASES ACTIONS A.1. A.2. and A.3 (A.3.1 or A.3.2.1 and A.3.2.2) (continued)

The charger operating in the current limit mode in excess of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is an indication that the battery is partially discharged and its capacity margins will be reduced. The time to return the battery to its full.y charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be fully recharged within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Required Action A.2).

Required Action A.2 requires that the battery float current be verified as less. than or equal to 21.50 amps. This indicates that, if the battery had been discharged as the result of the inoperable battery charger, it is now fully capable to supply the maximum expected load requirement.

The battery manufacturer certified that at 1.50 amps the battery is at least 98% charged. A 2' capacity margin (correction factor) has been used in the battery sizing calculation (Ref. 3) which ensures that the battery has sufficient capacity to meet the maximum expected load demand. If at the expiration of the initial 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months period the battery float current is not less than or equal to 1.50 amps this indicates there may be additional battery problems and the battery must be declared inoperable..

A digital multimeter of high accuracy in an average function mode is required to measure the steady state float charging current (Ref. 4). The multimeter must be capable of measuring the low magnitude of DC current (less than 1.50 amps) and filtering the induced AC noise from the connected inverter. A millivolt shunt located close to the battery terminal provides the battery float charging current signal.

Required Action A.3 (A.3.1 or A.3.2.1 and A.3.2.2) is applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been used (e.g., balance of plant non-Class 1E spare battery charger).

Required Action A.3.1 limits the restoration time for the required battery charger to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months if a non-lE charger with a non-iE power source is used. The restoration time for the battery charger can be extended to 7 days (required Action A.3.2.2) if the ability to power the spare battery charger from a diesel-backed source has been established within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (Required Action A.3.2.1). All preparations to accomplish the ability to power the spare battery charger must be complete within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The purpose of this (continued)

SAN ONOFRE--UNIT 2 B 3.8-59 Amendment No. 127 03/13/09

DC Sources -Shutdown B 3.8.5 BASES ACTIONS A.1, A.2. and A.3 (A.3.1 or A.3.2.1 and A.3.2.2) (continued) provision is to facilitate connection of the spare battery charger to a diesel-backed source in

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months if non-iE power is lost. The 4-hour charger connection time is required because 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after the loss of non-iE power, the battery may not supply the minimum required voltage at the loads. The 7-day completion time reflects a reasonable time to effect restoration of the required battery charger to operable status.

B.I. B.2. and B.3 (B.3.1 or B.3.2.1 and B.3.2.2)

Condition B is modified by a NOTE identifying that it is only applicable to 1260 amp-hour rated batteries.

Required Action B.1 basis is the same as A.I.

Required Action B.2 requires that the battery float current be verified to be less than or equal to 0.75 amp. This indicates that, if the batteryý.had been discharged as the result of the inoperable battery charger, it is now fully capable to supply the maximum expected load requirement.

The battery manufacturer certified that at 0.75 amp the battery is at least 98% charged. A 2% capacity margin (correction factor) has-been used in the battery sizing calculation (Ref. 3) which ensures that the battery has sufficient capacity to meet the maximum expected load demand. If at the expiration of the initial 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months period the battery float current is not less than or equal to 0.75 amp this indicates there may be additional battery problems and the battery must be declared inoperable.

A digital multimeter of high accuracy in an average function mode is required to measure the steady state float charging current (Ref. 4). The multimeter must be capable of measuring the low magnitude of DC current (less than 0.75 amp) and filtering the indicated AC noise from the connected inverter. A millivolt shunt located close to the battery terminal provides the battery float charging current signal.

Required Action B.3 (B.3.1 or B.3.2.1 and B.3.2.2) basis is the same as A.3 (A.3.1 or A.3.2.1 and A.3.2.2).

(continued)

SAN ONOFRE--UNIT 2 B 3.8-59a Amendment No. 127 03/13/09

DC Sources- Shutdown B 3.8.5 BASES ACTIONS C.1 (continued)

With the required DC electrical power subsystem battery charger or associated control equipment or cabling outside the allowances of the Required Actions for Condition A or B, sufficient capacity to supply the maximum expected load requirement is not assured and the associated DC battery must be declared inoperable immediately.

D.I. or.D.2.1, D.2.2, D.2.3, D.2.4. andAD2.5:

Condition D represents one DC electrical power subsystem inoperable for reasons other than Condition A or B including when a battery is inoperable (Condition C). The ACTIONS provide a tiered response allowing the option to declare required features inoperable immediately with the associated DC power source(s) inoperable.

If two trains are required per LCO 3.8.10, the remaining train with DC power available may be capable of supporting sufficient systems to allow continuation of CORE ALTERATIONS and fuel movement. By allowing the option to declare required features inoperable with the associated DC power source(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCO ACTIONS. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservatnis made (i.e., to suspend CORE ALTERATIONS, movement of irria-d-iat+ed fuel assemblie~s-witAin containment,"idg' -uspen moee ffe asmisi he ul trage pool, ýand:ý

ýu ndýratiosinovigps it ive reactivity ad ions . The Required Action to suspend positive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory, provided the required SDM is-maintained.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition.

These actions minimize probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC electrical power subsystems and to continue this action until restoration is accomplished in order to provide the necessary DC electrical power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required DC electrical power subsystems should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be without sufficient power.

(continued)

SAN ONOFRE--UNIT 2 B 3.8-59b Amendment No. 127 03/13/0

DC Sources- Shutdown B 3.8.5 BASES (continued)

SURVEILLANCE SR 3.8.5.1 REQUIREMENTS SR 3.8.5.1 states that Surveillances required by SR 3.8.4.1 through'SR 3.8.4.34 are applicable in these MODES. See the corresponding Bases for LCO 3.8.4 for a discussion of each SR.

This SR is modified by a NOTE. The reason for the NOTE is to preclude requiring the OPERABLE DC sources from being discharged below their capability to provide the required power supply or otherwise rendered inoperable during the performance of SRs. It is the intent that these SRs must still be capable of being met, but actual performance is not required.

REFERENCES I. UFSAR, Chapter 6.

2. UFSAR, Chapter 15.

3. SCE Calculation E4C-017.

4. Response to Request for Additional Information on Battery. and DC Sources Upgrades dated November 14, 2008.

(continued)

SAN ONOFRE--UNIT 2 B 3.8-59c Amendment No. 127 03/13/09

Inverters - Shutdown B 3.8.8 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.8 Inverters-Shutdown BASES BACKGROUND A description of the inverters is provided in the Bases for LCO 3.8.7, "Inverters-Operating."

APPLICABLE The initial conditions of Design Basis Accident (DBA) and SAFETY ANALYSES transient analyses in the UFSAR, Chapter 6 (Ref. 1) and Chapter 15 (Ref. 2), assume Engineered Safety Feature systems are OPERABLE. The DC to AC inverters are designed to provide the required capacity, capability, redundancy, and reliability to ensure the availability of necessary

..power to the Reactor Protective System and Engineered Safety Features Actuation System instrumentation and controls so that the fuel,. Reactor, Coolant System, and containment design limits are not exceeded.

The OPERABILITY of the inverters is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum inverters to each AC vital bus during MODES 5 and 6 ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods;

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

c. Adequate power is available to mitigate events postulated during shutdown, such as a fuel handling

accident.

The inverters were previously identified as part of-the distribution system and, as.such, satisfy Criterion 3 of the NRC Policy Statement.

(continued)

SAN ONOFRE--UNIT 2 B 3.8-71 Amendment No. 127

Inverters- Shutdown B 3.8.8 BASES (continued)

LCO The required inverters ensure the availability of electrical power for the instrumentation for systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA.

The battery powered inverters provide uninterruptible supply of AC electrical power to the AC vital buses even if the 4.16 kV safety buses are de-energized. OPERABILITY of at least two of the four inverters and the associated vital buses is required. This ensures the availability of sufficient inverter power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

APPLICABILITY The inverters required to be OPERABLE in MODES 5 and 6, frd

a. Systems to provide are availabie adequate for the coolant irradiated fuelinventory makeup in the *core;

b. Systems needed to mitigate a fuel handling accident are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

Inverter requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.7.

fuel, noný-

C h emfuIasmlyicue irradiated ir~dae ul n h um ulassembly.

ACTIONS A.1, A.2.1, A.2.2, A.2.3. A.2.4, and?.2 If two trains of 120 VAC Vital Buses are required by LCO 3.8.10, "Distribution Systems-Shutdown," the remaining OPERABLE inverters may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS, fuel movement, and operations with a potential for positive (continued)

SAN ONOFRE--UNIT 2 B 3.8-72 Amendment No. 127

Inverters - Shutdown B 3.8.8 BASES (continued)

ACTIONS A.1, A.2.1, A.2.2, A.2.3. A.2.4, andý.2. (continued) reactivity additions that could result in loss of required SDM (Mode 5) or boron concentration (Mode 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM. By the allowance of the option to declare required features inoperable with the associated inverter(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCOs' Required ACTIONS. In many instances, this option may involve undesired administrative efforts.

Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, and elsoaepol n use prtons invo ving positive reactivity additions).

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition.

These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required inverters and to continue this action until restoration is accomplished in order to provide the necessary inverter power to the unit safety systems.

Notwithstanding performance of the above conservative Required Actions, the unit is still without sufficient AC vital power sources to operate in a safe manner. Therefore, action must be initiated to' restore the minimum required AC vital power source and continue until the LCO requirements are restored.

(continued)

SAN ONOFRE--UNIT 2 B 3.8-73 Amendment No. +-2-7L,175

Inverters- Shutdown B 3.8.8 BASES (continued)

ACTIONS A.1, A.2.1, A.2.2, A.2.3, A.2.4. and5_\.2.5 (continued)

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required inverters should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power or powered from a constant voltage source transformer.

SURVEILLANCE SR 3.8.8.1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and AC vital buses energized from the inverter. The verification of proper voltage output ensures that the required power is readily available for the instrumentation connected to the AC vital buses. The 7 day Frequency takes into account the redundant capability of the inverters and other indications available in the control room that alert the operator to inverter malfunctions.

REFERENCES 1. UFSAR, Chapter 6.

2. UFSAR, Chapter 15.

SAN ONOFRE--UNIT 2 B 3.8-74 Amendment No. +,2-1,75 12/20/00 I

Distribution Systems - Shutdown B 3.8.10 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.10 Distribution Systems- Shutdown BASES BACKGROUND A description of the AC, DC, and AC vital bus electrical power distribution systems is provided in the Bases for.

LCO 3.8.9, "Distribution Systems(Operating" and the Bases for LCO 3.8.5, "DC Sources - Shutdown."

APPLICABLE The initial conditions of Design Basis Accident and SAFETY ANALYSES transient analyses in the UFSAR, Chapter 6 (Ref. 1) and Chapter 15 (Ref. 2), assume Engineered Safety Feature (ESF) systems are OPERABLE. The AC, DC, and AC vital bus electrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.

The OPERABILITY of the AC, and DC, electrical power distribution systems and AC vital buses is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum AC, and DC electrical power distribution systems, and AC vital buses during MODES 5 and 6 ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods;

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

c. Adequate power is provided to mitigate events postulated during shutdown, such as a fuel handling accident.

The AC and DC electrical power distribution systems satisfy Criterion 3 of the NRC Policy Statement.

(continued)

SAN ONOFRE--UNIT 2 B 3.8-84 Amendment No. 127 03/13/09

Distribution Systems -Shutdown B 3.8.10 BASES (continued)

LCO Various combinations of subelectrical distribution systems, equipment, and components are required OPERABLE by other LCOs, depending on the specific unit condition. Implicit in those requirements is the required OPERABILITY of necessary support required features. This LCO explicitly requires energization of the portions of the electrical distribution system necessary to support OPERABILITY of required systems, equipment and components(all specifically addressed in each LCO and implicitly required via the definition of OPERABILITY.

Maintaining these portions of the distribution system energized ensures the availability of sufficient power to operate the unit in a safe manner to mitigate the consequences of postulated events during shutdown (e.g.,

fuel handling accidents).

APPLICABILITY The AC and DC electrical power distribution systems required to be OPERABLE in MODES 5 and 6, ftfrd during movement of irradiated4 fuel assembli'es within containment, and during ve ofueasemblies in the fuel- storage pool, _,-

provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core;

b. Systems needed to mitigate a fuel handling accident are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition and refueling condition.

The AC, and DC electrical power distribution systems, and AC vital buses requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.9.

The term fuel assembly includes irradiated fuel, non-

irradiated fuel, and the dummy fuel assembly.

(continued)

SAN ONOFRE--UNIT 2 B 3.8-85 Amendment No. 127 93/13/09

Distribution Systems -Shutdown B 3.8.10 BASES (continued)

ACTIONS A.1, A.2.1, A.2.2. A.2.3. A.2.4, A.2.5, and W.6 Although redundant required features may require redundant trains of electrical power distribution subsystems to be OPERABLE, one OPERABLE distribution system may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and fuel movement. By allowing the option to declare required features associated with an inoperable distribution system inoperable, appropriate restrictions are implemented in accordance with the affected distribution systems LCO's Required Actions. In many *instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservatiy eactions is made (i.e., to-..suspend CORE ALTERATION "nd su e movement of i44o;dae fuel

assemblies within containmnent, anda s'us end' movem!ient fue

ass m *es in t e el stora pool and sus e dI operations involving positive rea ivity a ditions' that could result in loss of required SM (Mode 5) or boron concentration (Mode 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than what Would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation.

Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition.

These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC and DC electrical power distribution subsystems and to continue this action until restoration is accomplished in order to provide the necessary power to the unit safety systems.

Notwithstanding performance of the above conservative Required Actions, a required shutdown cooling (SDC) system may be inoperable. In this case, these Required Actions of Condition A do not adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LCO 3.0.6, the SDC ACTIONS would not be entered.

(continued)

SAN ONOFRE--UNIT 2 B 3.8-86 Amendment No. 127 03/13/* 9

Distribution Systems -Shutdown B 3.8.10 BASES (continued)

ACTIONS A.1, A.2.1. A.2.21, A.2.3, A.2.4, A.2-5 an4A.2Q.6 (continued)

Therefore, the Required Actions of Condition A direct declaring SDC inoperable, which results in taking the appropriate SDC actions.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required distribution systems should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power.

SURVEILLANCE SR 3.8.10.1 REQUIREMENTS This Surveillance verifies that the AC, DC, and AC vital bus electrical power distribution system is.functioning properly, with all the required buses energized. The verification of proper voltage availability on the buses ensures that the required power is readily available for motive as well as control functions for critical system loads connected to these buses. The 7-day frequency takes into account the redundant capability of the electrical power distribution systems and other indications available in the control room that alert the operator to subsystem malfunctions.

REFERENCES 1. UFSAR, Chapter 6.

2. UFSAR, Chapter 15.

(continued)

SAN ONOFRE--UNIT 2 B 3.8-87 Amendment No. 127 03/13/09

Containment Penetrations B 3.9.3 B 3.9 REFUELING OPERATIONS B 3.9.3 Containment Penetrations BASES BACKGROUND During CORE ALTERATIONS or movement of fuel assemblies within containment with irradiated fuel in containment, a release of fission product radioactivity within the containment will be restricted from escaping to the environment when the LCO requirements are met. In MODES 1, 2, 3, and 4, this is accomplished by maintaining containment OPERABLE as described in LCO 3.6.1, "Containment." In MODE 6, the potential for containment pressurization as a result of an accident is not likely; therefore, requirements to isolate the containment from the outside atmosphere can be less stringent. The LCO requirements are referred to as "containment closure" rather than "containment OPERABILITY."

Containment closure means that all potential escape paths are closed or capable of being closed. Since there is no potential for containment pressurization, the Appendix J, Option B leakage criteria and tests are not required.

The containment serves to contain fission product radioactivity that may be released from the reactor core following an accident, such that offsite radiation exposures are maintained well within the requirements of 10 CFR 100.

Additionally, the containment structure provides radiation shielding from the fission products that may be present in the containment atmosphere following accident conditions.

The containment equipment hatch, which is part of the containment pressure boundary, provides a means for moving large equipment and components into and out of containment.

During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, the equipment hatch must be held in place by at least four bolts. Good engineering practice dictates that the bolts required by this LCO be approximately equally spaced.

The containment air locks, which are also part of the containment pressure boundary, provide a means for personnel access during MODES 1, 2, 3, and 4 operation in accordance with LCO 3.6.2, "Containment Air Locks." Each air lock has a door at both ends. The doors are normally interlocked to prevent simultaneous opening when containment OPERABILITY is required. During periods of shutdown when containment (continued)

SAN ONOFRE--UNIT 2 B 3.9-9 Amendment No. 127 12/1/'98

Containment Penetrations B 3.9.3 BASES (continued)

BACKGROUND closure is not required, the door interlock mechanism may be (continued) disabled, allowing both doors of an air lock to remain open for extended periods when frequent containment entry is necessary. During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, containment closure is required; therefore, the door interlock mechanism may remain disabled, but one air lock door must always remain closed or operable. Operability of the containment personnel airlock door requires that the door is capable of being closed; that the door is unblocked and no cables or hoses are being run through the airlock; and that a designated individual is continuously available to close the airlock door. This individual must be stationed at the outer airlock door.

The use of temporary ramps for equipment access through the containment personnel air lock doors is acceptable during CORE ALTERATIONS or moving of +/-rradi-ted fuel within containment. These ramps do not impede closure of the containment personnel airlock doors as the ramps are quickly removed by the designated individual stationed at the outer door. Removal of the ramps is a normal function of door closure, and the ability of plant personnel to close the personnel airlock, if needed, is not compromised by the ramps. Similarly, door seal covers may be used, provided they are removed prior to air lock door closure.

Except the systems that are closed inside of containment, systems conducting a fluid in and/or out of containment can also satisfy LCO 3.9.3 in either of the following configurations:

a. Systems containing devices inside containment which would preclude free air flow from containment such as self-c losing quick disconnects, relief valves venting to containment, check valve(s), five foot water seal (periodic seal verification required), reciprocating pump, pipe cap, or any other equivalent device which would preclude free air flow out of containment.

b. Systems containing devices outside containment which would preclude free air flow from containment such as a reciprocating air compressor, compressed gas cylinder, or any of the devices listed in "a". above.

(continued)

SAN ONOFRE--UNIT 2 B 3.9.-10 Amendment No. +2-7-,193 02/18/105

Containment Penetrations B 3.9.3 BASES (continued)

BACKGROUND These closure devices and lines connecting them to (continued) containment should be nonflammable and are not subject to Local Leak Rate Testing. Small bore tubing and flexible lines need not be seismically supported but should be protected from damage which could affect Containment Closure.

The routing of temporary services, such as breathing air through opened penetrations during fuel movement is permissible if the following conditions are established:

a. The area surrounding the service passing through the containment wall shall be sealed. This criteria may be met by using an existing pipe or cable penetration or by providing a method of sealing around the service pipe, hose or cable at the containment wall such that there can be no free passage of air between the containment atmosphere and the outside atmosphere.

b. If the service carries a liquid or gas, at least one end shall be closed such that there can be no free assage of air through the service hose or pipe etween the containment atmosphere and the outside atmosphere. This requirement shall be able to be met even if pressure or flow is lost in the service system.

Check valves serving these lines prevent backflow from the containment atmosphere to the outside atmosphere.

Procedures for fulfilling proposed SURVEILLANCE REQUIREMENT 3.9.3.1 should contain provisions for identifying temporary services penetrating containment, and for determining that such penetrations satisfy the above criteria prior to fuel movement and periodically during fuel movement.

The requirements on containment penetration closure ensure that a release of fission product radioactivity within containment will be restricted from escaping to the environment.

The Containment Purge System includes two subsystems. The normal subsystem includes a 42 inch purge penetration and a 42 inch exhaust penetration. The second subsystem, a minipurge system, includes an 8 inch purge penetration and (conti nued)

SAN ONOFRE--UNIT 2 B 3.9-11 Amendment No. 127 10/10/97

Containment Penetrations B 3.9.3 BASES (continued)

BACKGROUND an 8 inch exhaust penetration. During MODES 1, 2, 3, and 4, (conti nued) the two valves in each of the normal purge and exhaust penetrations are secured in the closed position. The two valves in each of the two minipurge penetrations can be opened intermittently, but are closed automatically by the Containment Purge Isolation Signal (CPIS). Neither of the subsystems is subject to a Specification in MODE 5.

In MODE 6, large air exchanges are necessary to conduct refueling operations. The normal 42 inch purge system is used for this purpose and all valves are closed by the CPIS in accordance with LCO 3.3.8, "Containment Purge Isolation Signal (CPIS)."

The minipurge system is not normally used in MODE 6 with all four 8 inch valves in the closed position. However, as an alternative to normal purge, the minipurge system may be used in MODE 6 with CPIS operable.

The other containment penetrations that provide direct access from containment atmosphere to outside atmosphere must be isolated on at least one-side. Isolation may be achieved by an OPERABLE automatic isolation valve, or by a manual isolation valve, blind flange, or equivalent.

Equivalent isolation methods must be approved and may include use of a material that can provide a temporary atmosphericpressure ventilation barrier for the other containment penetrations during fuel movements.

APPLICABLE During CORE ALTERATIONS or movement of irradid fuel SAFETY ANALYSIS assemblies within containment, the most severe radiological consequences result from a fuel handling accident. The fuel handling accident is a postulated event that involves damage to irradiated fuel (Ref. 1). Fuel handling accidents include dropping a single irradiaed fuel assembly and handling tool or a heavy object onto othe- irradiated fuel assemblies. The requirements of LCO 3.9.6, "Refueling Water Level," and the minimum decay time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months prior to CORE ALTERATIONS ensure that the release of fission product radioactivity, subsequent to a fuel handling accident, results in doses that are well within the guideline values specified in 10 CFR 100.

Containment penetrations satisfy Criterion 3 of the NRC Policy Statement.

(continued)

SAN ONOFRE--UNIT 2 B 3.9-12 Amendment No. 127 10,10n97

Containment Penetrations B 3.9.3 BASES (continued)

LCO This LCO limits the consequences of a fuel handling accident in containment by limiting the potential escape paths for fission product radioactivity released within containment.

The LCO requires any penetration providing direct access from the containment atmosphere to the outside atmosphere to be closed except for the OPERABLE containment purge and exhaust penetrations and the containment personnel airlock.

For the containment personnel airlock, this LCO ensures that the airlock can be closed after containment evacuation in the event of a fuel handling accident. The requirement that the plant be in Mode 6 with 23 feet of water above the fuel in the reactor vessel or defueled configuration with fuel in the containment (i.e., fuel in the refueling machine or upender) ensures that there is sufficient time to close the ersonnel airlock following a loss of shutdown cooling efore boiling occurs.

LCO part a. is modified by a NOTE:

S-------------------------NOTE -----------------------

The equipment hatch may be open if all of the following conditions are met:

i) The Containment Structure Equipment Hatch Shield Doors are capable of being closed within 30 minutes,

2) The plant is in Mode 6 with at least 23 feet of water above the reactor vessel flange,

3) A designated crew is available to close the Containment Structure Equipment Hatch Shield Doors, 4 Containment purge is in service, and 5f The reactor has been subcritical for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

These restrictions include the administrative controls to allow the opening of the containment equipment hatch during CORE ALTERATIONS or movement of irradiated fuel in the containment provided that 1) The Containment Structure Equipment Hatch Shield Doors are capable of being closed within 30 minutes, 2) The plant is in Mode 6 with at least 23 feet of water above the reactor vessel flange, 3) A designated crew is available to close the Containment Structure Equipment Hatch Shield Doors, 4) Containment purge is in service, and 5) The reactor shall be subcritical for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The Containment Structure Equipment Hatch Shield Doors include flashing on the top and sides of the shield doors which act to retard or restrict a release of post-accident fission products. The capability to close the containment shield doors includes requirements that the doors are capable of being closed and that any cables or hoses across the opening have quick disconnects to ensure the doors are capable of being closed within 30 minutes.

(continued)

SAN ONOFRE--UNIT 2 B 3.9-13 Amendment No.-1--7-,193

Containment Penetrations B 3.9.3 BASES (continued)

LCO The 30 minute closure time for the containment shield doors (continued) is considered to start when the control room communicates the need to shut the Containment Structure Equipment Hatch Shield Doors. This 30-minute requirement is significantly less than the fuel handling accident analysis assumption that the containment remains open to the outside environment for a two-hour period subsequent to the accident. Placing containment purge (i.e., main purge exhaust with or without supply) in service will ensure any release from containment will be monitored.

The administrative controls will also specify the responsibility to be able to communicate with the control room, and specify the responsibility to ensure that the containment shield doors are capable of being closed in the event of a fuel handling accident. These administrative controls will ensure containment closure would be established in the event of a fuel handling accident inside containment.

LCO part b. is modified by a NOTE which allows both doors of the containment airlock to be open provided:

a. one personnel airlock door is OPERABLE, and b.1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel, or b.2 defueled configuration with fuel in containment (i.e., fuel in refueling machine or upender).

The OPERABILITY requirements ensure that the airlock door is capable of performing its function, and that a designated individual located outside of the affected area is available to close the door. For the OPERABLE containment purge and exhaust penetrations, this LCO ensures that these penetrations are isolable by the Containment Purge Isolation System. The OPERABILITY requirements for this LCO ensure that the automatic purge and exhaust valve closure times specified in the UFSAR can be achieved and therefore meet e assumptions used in the safety analysis to ensure releases through the valves are terminated, such that the radiological doses are within the acceptance limit.

APPLICABILITY The containment penetration requirements are applicable during CORE ALTERATIONS or movement of ir-raddi-ated fuel li .e', irra audue , and the dumm fel assembl ithin containment because this is when there is a p~otential for a fuel handling accident. In MODES 1, 2, 3, (continued)

SAN ONOFRE--UNIT 2 B 3.9-13a Amendment No.-2-7T193 02 o/48/05 1

Containment Penetrations B 3.9.3 BASES (continued)

APPLICABILITY and 4, containment penetration requirements are addressed by (continued) LCO 3.6.1, "Containment." In MODES 5 and 6, when CORE ALTERATIONS or movement of irradiated fuel assemblies within containment are not being conducted, the potential for a fuel handling accident does not exist. Therefore, under these conditions no requirements are placed on containment penetration status ACTIONS A.1 and A.2 With the containment equipment hatch, air locks, or any containment penetration that provides direct access from the containment atmosphere to the outside atmosphere not in the required status, including the Containment Purge Isolation System not capable of automatic actuation when the purge and exhaust valves are open, the unit must be placed in a condition in which the isolation function is not needed.

This is accomplished by immediately suspending CORE ALTERATIONS and movement of irradiated fuel assemblies within containment. Performance of these actions shall not preclude completion of movement of a component to a safe position.

SURVEILLANCE SR 3.9.3.1 REQUIREMENTS This Surveillance demonstrates that each of the containment penetrations required to be in its closed position is in that position. The Surveillance on the open purge and exhaust valves will demonstrate that the valves are not blocked from closing. Also, the Surveillance will demonstrate that each valve operator has motive power, which will ensure each valve is capable of being closed by an OPERABLE automatic Containment Purge Isolation Signal (CPIS).

The Surveillance is performed every 7 days during CORE ALTERATIONS or movement of irradiated fuel assemblies within the containment. As such, this Surveillance ensures that a postulated fuel handling accident that releases fission product radioactivity within the containment will not result in a release of fission product radioactivity to the environment.

(continued)

SAN ONOFRE--UNIT 2 B 3.9-14 Amendment No. 127

Containment Penetrations B 3.9.3 BASES (continued)

SURVEILLANCE SR 3.9.3.2 REQUIREMENTS This Surveillance demonstrates that each containment purge and exhaust valve actuates to its isolation position on an actual or simulated high radiation signal. The 24 month Frequency maintains consistency with other similar ESFAS instrumentation and valve testing requirements. In LCO 3.3.8, "Containment Purge Isolation Signal," the Containment Purge Isolation Signal requires a CHANNEL CHECK every 7 days and a CHANNEL FUNCTIONAL TEST every 92 days to ensure the channel OPERABILITY during refueling operations.

Every 24 months a CHANNEL CALIBRATION is performed. The signal actuation response time is demonstrated every 24 months, during refueling, on a STAGGERED TEST BASIS.

SR 3.6.3.5 demonstrates that the isolation time of each valve is in accordance with the Inservice Testing Program requirements. These surveillances will ensure that the valves are capable of closing after postulated fuel handling accident to limit a release of fission product radioactivity from the containment.

REFERENCE 1. NUREG-0712, Safety Evaluation Report related to the operation of San Onofre Nuclear Generating Station, Units 2 and 3, February 1981.

SAN ONOFRE--UNIT 2 8 3.9-15 Amendment No. 127 10/10/97

Refueling Water Level B 3.9.6 B 3.9 REFUELING OPERATIONS B 3.9.6 Refueling Water Level BASES BACKGROUND During movement of fuel assemblies or CEAs within the reactor pressure vessel When either the fuel assemblies being mfoved or the fuel assemfiblies seated within the reactor pressure vessel are irradiated, and during movement of

,rrd..t.e4 fuel assemblies within containment, a minimum water level of 23 ft above the top of the reactor vessel flange is required.. During refueling this maintains sufficient water level in the refueling canal and the fuel transfer canal. Sufficient water is necessary to retain iodine fission product activity in the water in the event of a fuel handling accident (Refs. 1 and 2). Sufficient iodine activity is well within the guidelines of IOCFR 100.

APPLICABLE Duig-oen offel assmle (i e.,irada edue SAFETY ANALYSES wr-'n-i-rra**-te -Jdtedmyfeýasmltheeouel w ereac or pr essure eth assemblies being moved or the fuel assemblies seated within the reaetor pressure vessel are irradiat , and during movement of irradiated fuel assemblies within containment, the water level in the refueling canal is an initial condition design parameter in the analysis of the fuel handling accident in containment postulated by Regulatory Guide 1.25 (Ref. 1). A minimum water level of 23 ft (Regulatory Position C.i.cof Ref. 1) allows a decontamination factor of 100 (Regulatory Position C.l.g of Ref..1) to be used in the accident analysis for iodine.

This relates to the assumption that 99% of the total iodine released from the pellet to cladding gap of all the dropped fuel assembly rods is retained by the refueling canal water.

The fuel pellet to cladding gap is assumed to contain 10% of the total fuel rod iodine inventory (Ref. 1).

The fuel handling accident analysis inside containment is described in Reference 2. With a minimum water level of 23 ft and a minimum decay time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months prior to fuel handling, the analysis and test programs demonstrate that the iodine release due to a postulated fuel handling accident is adequately captured by the water and offsite doses are maintained within allowable limits (Ref. 4).

Refueling water level satisfies Criterion 2 of the NRC Policy Statement.

(conti nued)

SAN ONOFRE--UNIT 2 B 3.9-25 Amendment No. 127 05/*//97

Refueling Water Level B 3.9.6 BASES (continued)

APPLICABLE The applicability statement is modified by a note which SAFETY ANALYSES allows that the water level may be lowered to a minimum of (continued) 23 feet above the top of the fuel for movement of four finger CEAs, coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling.

LCO A minimum refueling water level of 23 ft above the reactor vessel flange is required to ensure that the radiological consequences of a postulated fuel handling accident inside containment are within acceptable limits as provided by the guidance of Reference 3.

APPLICABILITY LCO 3.9.6 is applicable during movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fuel assemblies beimg mAved the fuel asse..bi.es seated with the rea.etr pressure vessel are irradiated, and during movement of irradiated fuel assemblies within containment.

A noteprovides an exception that the water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs, coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling. The LCO minimizes the possibility of a fuel handling accident in containment that is beyond the assumptions of the safety analysis. If irradiated fuel is not present in containment, there can be no significant radioactivity release as a result of a postulated fuel handling accident. Requirements for fuel handling accidents in the spent fuel pool are covered by LCO 3.7.16, ."Fuel Storage Pool Water Level."

ACTIONS A.1 and A.2 With a water level of < 23 ft above the top of the reactor vessel flange, all operations involving CORE ALTERATIONS or movement of irradiated fuel assemblies in containment shall be suspended immediately to ensure that a fuel handling accident cannot occur.

The suspension of CORE ALTERATIONS and fuel movement shall not preclude completion of movement of a component to a safe position.

(continued)

SAN ONOFRE--UNIT 2 B 3.9-26 Amendment No. 127 10/13/98

Refueling Water Level B 3.9.6 BASES (continued)

SURVEILLANCE SR 3.9.6.1 REQUIREMENTS Verification of a minimum water level of 23 ft,above the top of the reactor vessel flange ensures that the design basis for the postulated fuel handling accident analysis during refueling operations is met. Water at the required level above the top of the reactor vessel flange limits the consequences of damaged fuel rods that are postulated to result from a fuel handling accident inside containment (Ref. 2).

The Frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is based on engineering judgment and is considered adequate in view of the large volume of water and the normal procedural controls of valve positions, which make significant unplanned level changes unlikely.

REFERENCES 1. Regulatory Guide 1.25, March 23, 1972.°

2. UFSAR, Section 15.7.3.9.

3. NUREG-0712, Safety Evaluation Report related to the operation of San Onofre Nuclear Generating Station, Units 2 and 3, February 1981.

4. 10 CFR 100.10.

(conti nued)

SAN ONOFRE--UNIT 2 B 3.9-27 Amendment No. 127 10/13/98

Enclosure:

Evaluation of Proposed Change PCN-593 Attachment 7 Proposed Technical Specifications Bases Markup Pages, Unit 3 (For Information Only)

CPIS B 3.3.8 B 3.3 INSTRUMENTATION B 3.3.8 Containment Purge Isolation Signal (CPIS)

BASES BACKGROUND This LCO encompasses the CPIS, which is a plant specific

.instrumentation channel that performs an actuation function required for plant protection but is not otherwise included in LCO 3.3.6, "Engineered Safety Features Actuation System (ESFAS) Logic and Manual Trip," or LCO 3.3.7, "Diesel Generator (DG)-Undervoltage Start."

A CPIS radiation monitor will generate a train related containment purge isolation signal (CPIS) upon detection of high gaseous radiation in containment. This signal in turn initiates a close signal to all same train containment purge valves, both main and minipurge.

The CPIS includes two independent, redundant logic subsystems, including actuation trains. Each train employs one gaseous sensor.

If either one of the corresponding sensors exceeds the bistable trip setpoint, the CPIS train will be actuated.

Each train actuates a separate series valve in the containment purge supply and return lines. Either train controls sufficient equipment to perform the isolation function. Minipurge valves are also isolated automatically on a Safety Injection Actuation Signal (SIAS) and Containment Isolation Actuation Signal (CIAS) in Modes 1-3.

Trip Setpoints The trip setpoint is set sufficiently high to prevent spurious alarms/trips yet sufficiently low to assure an alarm/trip should an inadvertent release occur. Compliance with this requirement provides suitable confirmation that the monitors are capable of performing their intended function.

(continued)

SAN ONOFRE--UNIT 3 B 3.3-135 Amendment No. 116 05/28/97

CPIS B 3.3.8 BASES (continued)

APPLICABLE The containment airborne radiation monitors will generate an SAFETY ANALYSES isolation signal for the containment purge in the event of a LOCA. However, containment isolation is expected to occur on either a safety injection actuation system signal or a containment isolation actuation system signal prior to initiation on a CPIS signal on high radiation in containment. In addition, the-calculations show that, following a fuel handling accident in containment due to the response time of the containment airborne radiation monitors there will be some release of radioactivity to the environment prior to isolation of the purge by the CPIS.

In order to calculate the off-site doses resulting from such a release, it was conservatively assumed that all of the airborne radioactivity resulting from a fuel handling accident in containment was released to the environment (i.e., the containment purge was not isolated following a fuel handling accident). The analysis showed that the 0-2 hour site boundary (exclusion area boundary [EAB]) thyroid dose and the 0-2 hour site boundary whole body (WB) dose would be below the Standard Review Plan (SRP) 15.7.4 limits of 75 rem thyroid and 6 rem WB (these' SRP limits are based on 25 percent of the 10 CFR 100 limits).

General Design Criteria (GDC) 19 specifies that adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem WB, or its equivalent to any part of the body, for the duration of the accident. SRP 6.4 defines the dose-equivalent to the thyroid as 30 rem. The analysis demonstrated that the dose values are below those specified in GDC 19 as delineated by SRP 6.4.

(continued)

SAN ONOFRE--UNIT.3 B 3.3-136 Amendment No. 116 06/09/00

CPIS B 3.3.8 BASES (continued)

LCO LCO 3.3.8 requires one CPIS channel to be OPERABLE. The required channel consists of gaseous radiation monitors; Actuation Logic; and Manual Trip.

The Bases for the LCO on CPIS are discussed below for each Function:

a. Manual Trip The LCO on Manual Trip backs up the automatic trip and ensures operators have the capability to rapidly initiate the CPIS Function if any parameter is trending toward its set.point. One manual channel of CPIS is required in MODES 1, 2, 3, and 4, since the CPIS is redundant with the CIAS and SIAS. One manual channel of CPIS is required during CORE ALTERATIONS and movement of irra.di.ated fuel assemblies, since there are additional means of closing the containment purge valves in the event of a channel failure.

b. Gaseous Airborne Radiation The monitor detects in containment gaseous airborne radiation and provides an alarm and trip function upon reaching the setpoint value. The trip function opens a contact in the actuation logic.. There are two monitors with input into redundant actuation trains.

c. Actuation Logic Actuation logic provides close signals to both mini and main train related containment purge valves.

APPLICABILITY In MODES 1, 2, 3, and 4, the minipurge valves may be open.

In these MODES, it is necessary to ensu.re the valves will shut in the event of a primary leak in containment whenever any of the containment purge valves are open.

With the purgeraat.fulasmle(ie, mveeto valves open during CORE ALTERATIONS or irradiated'-

um ulaseb ihnco imna fuel handlingi accident woul require CPIS on high radiation in containment.

(continued)

SAN ONOFRE--UNIT 3 B 3.3-137 Amendment No. 116 95/28/97

CPIS B 3.3.8 BASES (continued)

APPLICABILITY The APPLICABILITY is modified by a Note, which states that (Continued) the CPIS Specification is only required when the penetration is not isolated by appropriate closed and de-activated automatic valve(s), closed manual valve(s), or blind flange(s).

ACTIONS A CPIS channel is inoperable when it does not satisfy the OPERABILITY criteria for the channel's function. The most common cause of channel inoperability is outright failure or drift of the bistable or process module sufficient to exceed the tolerance allowed by the plant specific setpoint analysis. Typically, the drift is not large and would result in a delay of actuation rather than a total loss of function. This determination is generally made during the performance of a CHANNEL FUNCTIONAL TEST when the process instrument is set up for adjustment to bring it within specification. If the trip setpoint is not consistent with the value specified in the Surveillance Requirement SR 3.3.8.2, the channel must be declared inoperable immediately, and the appropriate Conditions must be entered.

In the event a channel's trip setpoint is found nonconservative with respect to the value specified in the Surveillance Requirement SR 3.3.8.2, or the sensor, instrument loop, signal processing electronics, or bistable is found inoperable, then all affected Functions provided by that channel are required to be declared inoperable and the LCO Condition entered for the particular protective function affected.

A.1 Condition A applies to the failure of CPIS, Actuation Logic, and gaseous radiation monitors. The Required Action is to enter the applicable Conditions and Required Actions for affected valves of LCO 3.6.3, "Containment Isolation Valves." The Completion Time accounts for the condition that the capability to isolate containment on valid containment high radiation or manual signals is degraded during power operation or shutdown modes.

(continued)

SAN ONOFRE--UNIT 3 R 3.3-138 Amendment No. 116 05/28/97

CPIS B 3.3.8 BASES (continued)

ACTIONS B.1 and B.2 (continued)

Condition B applies when the Required Action and associated Completion Time of Condition A are not met in MODE 1, 2, 3, or 4. If Required Action A cannot be met within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

C.1 Condition C applies when one or more required channels of gaseous airborne radiation monitors are inoperable. The appropriate action is to enter LCO 3.4.15.

D.1. D.2.1, and D.2.2 Condition D applies to the same conditions as are described in Condition A; however, the applicability is during CORE ALTERATIONS or during the movement of irradiated fuel assemblies within containment. Required Action D.1 is to place the containment purge and exhaust isolation valves in the closed position. The Required Action immediately performs the isolation function of the CPIS. Required Actions D.2.1 and D.2 2 may be performed in lieu of Required Action D.1. Required Action D.2.1 requires the suspension of CORE ALTERATIONS and Required Action D..2.2 requires suspension of movement of irradiated fuel in containment immediately. The Completion Time accounts for the fact that the automatic capability to isolate containment on valid containment high radiation signals is degraded during conditions in which a fuel handling accident is possible and CPIS provides the only automatic mitigation of radiation release.

SURVEILLANCE SR 3.3.8.1 REQUIREMENTS Performance of the CHANNEL CHECK once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ensures that a gross failure of instrumentation has not occurred on the required gaseous airborne radiation monitor channels used in.the CPIS. A CHANNEL CHECK is a comparison of the (continued)

SAN ONOFRE--UNIT 3 B 3.3-139 Amendment No. 116 0'28/197

CPIS B 3.3.8 BASES (continued)

SURVEILLANCE SR 3.3.8.1 (continued)

REQUIREMENTS parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value.

Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the match criteria, it may be an indication that the transmitter or the signal processing equipment has drifted outside its limit.

The Frequency, about once every shift, is based on operating experience that demonstrates the rarity of channel failure.

Thus, performance of the CHANNEL CHECK guarantees that undetected overt channel failure is limited to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Since the probability of two random failures in redundant channels in any 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months period is low, the CHANNEL CHECK minimizes the chance of loss of protective function due to failure of redundant channels. The CHANNEL CHECK supplements less formal, but more frequent, checks of channel OPERABILITY during normal operational use of the displays associated with the LCO required channels.

SR 3.3.8.2 A CHANNEL FUNCTIONAL TEST is performed on the required containment gaseous airborne radiation monitoring channel to ensure the entire channel will perform its intended function. Setpoints must be found as specified in SR 3.3.8.2 and left consistent with the assumptions of the setpoint analysis. The Frequency of 92 days is based on plant operating experience with regard to channel OPERABILITY and drift, which demonstrates that failure of more than one channel of a given Function in any 92 day Frequency is a rare event.

(continued)

SAN ONOFRE--UNIT 3 B 3.3-140 Amendment No. 116 05/28/97

CPIS B 3.3.8 BASES (continued)

SURVEILLANCE SR 3.3.8.3 REQUIREMENTS (Continued) Proper operation of the individual initiation relays is verified by actuatingthese relays during the CHANNEL FUNCTIONAL TEST of the Actuation Logic every 24 months.

This will actuate the Function, operating all associated equipment. Proper operation of the equipment actuated by each train is thus verified. The Frequency of 24 months is based on plant operating experience with regard to channel OPERABILITY and drift, which demonstrates that failure of more than one channel of a given Function during any 24 month interval is a rare event. A Note to the SR indicates that this Surveillance includes verification of operation for each initiation relay.

SR 3.3.8.4 CHANNEL CALIBRATION is a complete check of the instrument channel including the sensor. The Surveillance verifies that the channel responds to a measured parameter within the necessary range and accuracy. CHANNEL CALIBRATION leaves the channel adjusted to account for instrument drift between successive calibrations to ensure that the channel remains operational between successive surveillances. Measurement error determination, setpoint error determination, and calibration adjustment must be performed consistent with the plant specific setpoint analysis. The channel shall be left calibrated consistent with the assumptions of the current setpoint analysis.

The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power.

SR 3.3.8.5 This Surveillance ensures that the train actuation response times are less than or equal to the maximum times assumed in the analyses. The 24 month Frequency is based upon plant operating experience, which shows that random failures of instrumentation components causing serious response time degradation, but not channel failure, are infrequent occurrences. Testing of the final actuating devices, which make up the bulk of the response time, is included in the Surveillance.

(continued)

SAN ONOFRE--UNIT 3 B 3.3-14"1 Amendment No. 116 05/28/97

CPIS B 3.3.8 BASES (continued)

SURVEILLANCE SR 3.3.8.6 REQUIREMENTS (Continued) Every 24 months, a CHANNEL FUNCTIONAL TEST is performed on the CPIS Manual Trip channel.

This test verifies that the trip push buttons are capable of opening contacts in the Actuation Logic as designed, de-energizing the initiation relays and providing manual actuation of the Function. The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown these components usually pass the Surveillance when performed at a Frequency of once every 24 months.

REFERENCES 1. SONGS Units 2 and 3 UFSAR, Chapter 15.

2. 10 CFR 100.

SAN ONOFRE--UNIT 3 B 3.3-142 Amendment No. 116 05/28/97

CPIS B 3.3.8 BASES (continued)

THIS PAGE INTENTIONALLY LEFT BLANK SAN ONOFRE--UNIT j B 3.3-143 Amendment No. 116 05/28/97

CPIS B 3.3.8 BASES (continued)

THIS PAGE INTENTIONALLY LEFT BLANK

.SAN ONOFRE--UNIT 3 B 3.3-144 Amendment No. 116 05/28/97

CRIS B 3.3.9 B 3.3 INSTRUMENTATION B 3.3.9 Control Room Isolation Signal (CRIS)

BASES BACKGROUND This LCO encompasses CRIS actuation, which is a plant specific instrumentation channel that performs an actuation function required for plant protection but is not otherwise included in LCO 3.3.6, "Engineered. Safety Features Actuation System (ESFAS) Logic and Manual Trip," or LCO 3.3.7, "Diesel Generator (DG) -Loss of Voltage Start (LOVS)." This is a non-Nuclear Steam Supply System ESFAS Function that, because of differences in purpose, design, and operating requirements, is not included in LCO 3.3.6 and LCO 3.3.7.

The CRIS terminates the normal supply of outside air to the control room and initiates actuation of the Control Room Emergency Air Cleanup System (CREACUS) to minimize operator radiation exposure. The CRIS includes two independent, redundant trains. Each train consists of a gaseous radiation monitor, manual trip function and actuation logic.

If the bistable monitoring either sensor indicates an unsafe condition, that train will be actuated (one-out-of-two logic). Each trainrelated actuation signal operates the same train isolation equipment. Actuating either train will perform the intended function' Control room isolation also occurs on a Safety Injection Actuation Signal (SIAS) in MODES 1, 2, and 3.

Trip Setpoint Accidents crediting control room isolation from the CRIS radiation monitor(s) have been evaluated with the setpoint specified in the Surveillance Requirement. The resulting dose to the control room operators is within the 10CFR50 Appendix A General Design Criteria 19-1imits.

(continued)

SAN ONOFRE--UNIT 3 B 3.3-145 Amendment No. 116 06/27/97

CRIS B 3.3.9 BASES (continued)

APPLICABLE The CRIS, in conjunction with the Control Room Emergency Air SAFETY ANALYSES Cleanup System (CREACUS), maintains the control room atmosphere within conditions suitable for prolonged occupancy throughout the duration of any one of the accidents discussed in Reference 1. The radiation exposure of control room personnel, through the duration of any one of the postulated accidents discussed in "Accident Analysis," SONGS Units 2 and 3 UFSAR, Chapter 15 (Ref. 1),

does not exceed.the limits set by 10 CFR 50, Appendix A, GDC 19 (Ref. 3).

LCO LCO 3.3.9 requires one channel of CRIS to be OPERABLE. The required channel consists of Actuation. Logic, Manual Trip, and gaseous radiation monitors. The specified value for the setpoint of the CRIS is listed in the SR.

The Bases for the LCO on the CRIS are discussed below for each Function:

a. Manual Trip The LCO on Manual Trip backs up the automatic trips and ensures operators have the capability to rapidly initiate the CRIS Function if any parameter is trending toward its setpoint. One channel must be OPERABLE. This considers that the Manual Trip capability is a backup and that other means are available to actuate the redundant train if required, including manual SIAS.

b. Airborne Radiation One channel of Airborne Radiation detection in the required train is required to be OPERABLE to ensure the control room isolates on high gaseous concentration.

c. Actuation Logic One train of Actuation Logic must be OPERABLE, since there are alternate means available to actuate the redundant train, including SIAS.

(continued)

SAN ONOFRE--UNIT 3 B 3.3-146 Amendment No. 116 12/01/08

CRIS B 3.3.9 BASES (continued)

APPLICABILITY The CRIS Functions must be OPERABLE in MODES 1, 2, 3, 4, 5 ACTIONS A CRIS channel is inoperable when it does not satisfy the OPERABILITY criteria for the channel's function. The most common cause of channel inoperability is outright failure or drift of the bistable or process module. Typically, the drift is not large and would result in a delay of actuation rather than a total loss of function. This determination is generally made during the performance of a CHANNEL FUNCTIONAL TEST when the process instrument is set up for adjustment to bring it within specification. If the trip setpoint is not within the specified value, the channel is inoperable and the appropriate Conditions must be entered, The provisions of LCO's 3.0.3 and 3.0.4 are not applicable to this specification, as indicated by the two NOTES.

A.1, B.I. B.2.1, B.2.2 and B Conditions A and B have been modified by a Note, which specifies that CREACUS be placed manually in the isolation mode if the automatic transfer to the isolation mode is inoperable.

Conditions A and B are applicable to manual and automatic actuation of the CREACUS by CRIS. Condition A applies to the failure of the CRIS Manual Trip, Actuation Logic, and required gaseous radiation monitor channels in MODE 1, 2, 3, or 4. Entry into this Condition requires action to either restore the failed channel(s) or manually perform the CRIS safety function (Required Action A.1). The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is sufficient to complete the Required Actions and accounts for the fact that CRIS supplements control room isolation by other Functions in MODES 1, 2, 3, and 4.

(continued)

SAN ONOFRE--UNIT 3 B 3.3-147 Amendment No. 116 o627/97

CRI S B 3.3.9 BASES (continued)

ACTIONS Condition B applies to the failure of CRIS Manual Trip, (continued) Actuation channels n Logic,do z-Hý4 or required

.. , gaseous Wrdiation monitor oý U t r i n ni at e m ACre r y a*ento QZ2 r eCoo T e~ui meiateI place one, RABLE R ACUS trainadditions,in the emergenc and s mode, emde or to suspend positive reactivity t of fuel assemblies in a mýenni dn inj fact that t~a ýo The Completion -e D i-es e the radiation signals are the only Functions available to initiate control room isolation in the event of a fuel handling accident.

Required Action B.2.2 is modified by a note to indicate that normal plant control operations that individually add limited positive reactivity (e.g., temperature or boron fluctuations associated with RCS inventory management or temperature control) are not precluded by this Action, provided they are accounted for in the calculated SDM.

SURVEILLANCE SR 3.3.9.1 REQUIREMENTS Performance of the CHANNEL CHECK once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ensures that a gross failure of instrumentation has not occurred. A CHANNEL CHECK is a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value.

Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

Agreement criteria are determined by the plant staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the match criteria, it may be an indication that the transmitter or the signal processing equipment has drifted outside its limit.

The Frequency, about once every shift, is based on operating experience that demonstrates the rarity of channel failure.

Thus, performance of the CHANNEL CHECK guarantees that undetected overt channel failure is limited to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Since the probability of two random failures in redundant channels in any 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months period is low, the CHANNEL CHECK minimizes the chance of loss of protective function due to failure of redundant channels. The CHANNEL CHECK (conti nued)

SAN ONOFRE--UNIT 3 B 3.3-148 Amendment No. -1+-6,166 12/20/1 0

CRIS B 3.3.9 BASES (continued)

SURVEILLANCE SR 3.3.9.1 (continued)

REQUIREMENTS supplements less formal, but more frequent, checks of channel OPERABILITY during normal operational use of the displays associated with the LCO required channels.

SR 3.3.9.2 A CHANNEL FUNCTIONAL TEST is performed on the required control room radiation monitoring channel to ensure the entire channel will perform its intended function. As found and as left setpoints are recorded.

The Frequency of 92 days is based on plant operating experience with regard to channel OPERABILITY and drift, which demonstrates that failure of more than one channel of a given Function in any 92 day interval is a rare event.

SR 3.3.9.3 Proper operation of the individual initiation relays is verified by de-energizing these relays during the CHANNEL FUNCTIONAL TEST of the Actuation Logic every 18 months.

This will actuate the Function, operating all associated equipment. Proper operation of the equipment actuated by each train is thus verified.

The Frequency of 18 months is based on plant operating experience with regard to channel OPERABILITY, which demonstrates that failure of more than one channel of a given Function in any 18 month interval is a rare event.

A Note indicates this Surveillance includes, verification of operation for each initiation relay.

SR 3.3.9.4 CHANNEL CALIBRATION is a complete check of the instrument channel including the sensor. The Surveillance verifies that the channel responds to a measured parameter within the necessary range and accuracy.

The Frequency of an 18 month calibration interval is based on experience with the magnitude of equipment drift in this period.

(conti nued)

SAN ONOFRE--UNIT 3 B 3.3-149 Amendment No. 1-+6,166 12/20/00 1

CRIS B 3.3.9 BASES (continued)

SURVEILLANCE SR 3.3.9.5 REQUIREMENTS (continued) Every 18 months, a CHANNEL FUNCTIONAL TEST is performed on the manual CRIS actuation circuitry.

This test verifies that the trip push buttons are capable of opening contacts in the Actuation Logic as designed, de-energizing the initiation relays and providing Manual Trip of the function. The 18 month Frequency is based on the need to perform this Surveillance under the conditions that apply during a plant outage and the potential for an unplanned transient if the Surveillance were performed with the reactor at power. Operating experience has shown these Components usually pass the Surveillance when performed at a Frequency of once every 18 months.

SR 3.3.9.6 This Surveillance ensures that the train actuation response times are less than or equal to the maximum times assumed in the analyses. A time limit to isolate the control room is needed to ensure compliance with 10. CFR,50 Appendix A General Design Criterion 19. The 18 month frequency is based upon plant operating experience, which shows that random failures of instrumentation components causing serious response time degradation, but not channel failure, are infrequent occurrences. The response time is tested from the module input; i.e., the radiation detector response is not measured. Testing of the final actuating devices is included in the Surveillance. Response time testing acceptance criteria a-e included in Reference 4.

REFERENCES i SONGS Units 2 and 3 UFSAR, Chapter 15.

2. SCE Calculation A-92-NF-003.

3. 10 CFR 50, Appendix A, GDC 19.

4. Licensee Controlled Specification 3.3.i00, "RPS/ESFAS Response Times."

SAN ONOFRE--UNIT 3 B 3.3-150 Amendment No. 116 12/02/99 Re-issued on 08/20/01

CRIS B 3.3.9 BASES (continued)

THIS PAGE INTENTIONALLY BLANK SAN ONOFRE--UNIT 3 B 3.3-151 Amendment No. 116 06/27/97

CREACUS B 3.7.11 B 3.7 PLANT SYSTEMS B 3.7.11 Control Room Emergency Air Cleanup System (CREACUS)

BASES BACKGROUND The CREACUS provides a protected environment from which occupants can control the plant following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.

The CREACUS consists of two independent, redundant trains that recirculate and filter air in the control room envelope (CRE) and a CRE boundary that limits the inleakage of unfiltered air. Each CREACUS train consists of emergency air conditioning unit, emergency ventilation air supply unit, emergency isolation dampers, and cooling coils and two cabinet coolers per Unit. Each emergency air conditioning unit includes a prefilter, a high efficiency particulate air (HEPA) filter, an activated carbon adsorber section for removal of gaseous activity (principally iodines), and a fan. A second bank of HEPA filters follows the adsorber section to collect carbon fines. Each emergency ventilation air supply unit includes prefilter, HEPA filter, carbon adsorber and fan. Ductwork, motor-operated dampers, doors, barriers, and instrumentation also form part of the system.

Air and motor-operated dampers are provided for air volume control and system isolation purposes.

The CRE is the area within the confines of the CRE boundary that contains the spaces that control room occupants inhabit to control the unit during normal and accident conditions.

This area encompasses the control room, and may encompass other non-critical areas to which frequent personnel access or continuous occupancy is not necessary in the event of an accident. The CRE is protected during normal operation, natural events, and accident conditions. The CRE boundary is the combination of walls, floor, roof, ducting, doors, penetrations and equipment that physically form the CRE.

The OPERABILITY of the CRE boundary must be maintained to ensure that the inleakage of unfiltered air into the CRE will not exceed the inleakage assumed in the licensing basis analyses of design basis accident (DBA) consequences to CRE occupants. The CRE and its boundary are defined in the Control Room Envelope Habitability Program.

(continued)

SAN ONOFRE--UNIT 3 B 3.7-56 Amendment No. 116 12/12/07

CREACUS B 3.7.11 BASES (continued)

BACKGROUND Upon receipt of the actuating signal, normal air supply to (continued) the CRE is isolated, and the stream of ventilation air is recirculated through the system's filter trains. The prefilters remove any large particles in the air to prevent excessive loading of the HEPA filters and charcoal adsorbers. Continuous operation of each train for at least 15 minutes per month verifies proper system operability.

There are two CREACUS operational modes. Emergency mode is an operational mode when the control room is isolated to protect operational personnel from radioactive exposure through the duration of any one of the postulated limiting faults discussed in Chapter 15 UFSAR (Ref. 2). Isolation mode is an operational mode when the CRE is isolated to protect operational personnel from toxic gasses and smoke.

Actuation of the CREACUS places the system into either of.

two separate states of operation, depending on the initiation signal. Actuation of the system to either the emergency mode r isolation mode of CREACUS operation.

closes the unfiltered-outside-air intake and unfiltered exhaust dampers, and aligns the system for recirculation of air within the CRE through the redundant trains of HEPA and charcoal filters.

The emergency mode also initiates pressurization of the CRE.

Outside air is added to the air being recirculated from the CRE. Pressurization of the CRE minimizes infiltration of unfiltered air through the CRE boundary from all the surrounding areas adjacent to the CRE boundary.

The CRE supply and the outside air supply of the normal control room HVAC are monitored by radiation and toxic-gas detectors respectively. One detector output above the setpoint will cause actuation of the emergency mode or isolation mode as required. The actions of the isolation mode are more restrictive, and will override the actions of the emergency mode of operation. However, toxic gas and radiation events are not considered to occur concurrently.

(continued)

SAN ONOFRE--UNIT 3 B 3.7-57 Amendment No. 116 12/12/07

CREACUS B 3.7.11 BASES (continued)

BACKGROUND Redundant recirculation trains provide the required (continued) filtration should an'excessive pressure drop develop across the other filter train. Normally-open isolation dampers are arranged in series pairs so that one damper's failure to shut will not result in a breach of isolation. The CREACUS is designed in accordance with Seismic Category I requirements.

The CREACUS is designed to maintain a habitable environment in the CRE for 30 days of continuous occupancy after a Design Basis Accident (DBA) without exceeding a 5-rem total effective dose equivalent (TEDE).

APPLICABLE The CREACUS components are arranged in redundant, safety SAFETY ANALYSES related ventilation trains. The location of components and ducting within the CRE ensures an adequate supply of filtered air to all areas requiring access.

The CREACUS provides airborne radiological protection for the CRE occupants, as demonstrated by the CRE occupant dose analyses for the most limiting design basis loss of coolant accident fission product release presented in the UFSAR, Chapter 15 (Ref. 2).

Dose calculations, as specified in Unit 2/3 UFSAR Chapter 15 (Reference 2), only take credit for the HEPA filters and charcoal adsorbers of the emergency recirculation air conditioning unit.. The emergency ventilation supply unit is designed to contribute to the pressurization of the control room to minimize unfiltered inleakage as indicated in Unit 2/3 UFSAR.

(continued)

SAN ONOFRE--UNIT 3 B 3.7-58 Amendment No. 116 12/12/07

CREACUS B 3.7.11.

BASES (continued)

APPLICABLE The CREACUS provides protection from smoke and hazardous SAFETY ANALYSES chemicals to the CRE occupants. The analysis of hazardous (continued) chemical releases demonstrates that the toxicity limits are not exceeded in the CRE following a hazardous chemical release (Ref. 3). The evaluation of a smoke challenge demonstrates that it will not result in the inability of the CRE occupants to control the reactor either from the control room or from the remote shutdown panels (Ref. 4).

The worst case single active failure of a component of the CREACUS, assuming a loss of offsite power, does not impair the ability of the system to perform its design function.

The CREACUS satisfies Criterion 3 of the NRC Policy Statement.

LCO Two independent and redundant trains of the CREACUS are required to be OPERABLE to ensure that at least one is available if a single active failure disables the other train. Total system failure, such as from a loss of both ventilation trains or from an inoperable CRE boundary, could result in exceeding a dose of 5 rem TEDE to the CRE occupants in the event of a large radioactive release.

Each CREACUS train is considered OPERABLE when the individual components necessary to limit CRE occupant exposure are OPERABLE. A CREACUS train is considered OPERABLE when the associated:

a. Fan is OPERABLE;

b. HEPA filters and charcoal adsorber are not excessively restricting flow, and are capable of performing their filtration functions; and (continued)

SAN ONOFRE--UNIT 3 B 3.7-59 Amendment No. 117 12/12/07

CREACUS B 3.7.11 BASES (continued)

LCO c. Ductwork, valves, and dampers are OPERABLE, and air (continued) circulation can be maintained. If an Emergency Isolation Damper is stuck open, the associated train of CREACUS may still be considered OPERABLE if the redundant damper in series with the inoperable damper is closed with power removed.

In order for the CREACUS trains to be considered OPERABLE, the CRE boundary must be maintained such that CRE occupant dose from a large radioactive release does not exceed the calculated dose in the licensing basis consequence analyses for DBAs, and that CRE occupants are protected from hazardous chemicals and. smoke.

The LCO is modified by a Note allowing the CRE boundary to be opened intermittently under administrative controls.

This note only applies to openings in the CRE boundary that can be rapidly restored to the design condition, such as doors, hatches, floor plugs, and access panels. For entry and exit through doors the administrative control of the opening is performed by the person(s) entering or exiting the area. For other openings, these controls should be proceduralized and consist of stationing a dedicated individual at the opening who is in continuous communication with the operators in the CRE. This individual will have a method to rapidly close the opening and to restore the CRE boundary to a condition equivalent to the design condition when a need for CRE isolation is indicated.

(continued)

SAN ONOFRE--UNIT 3 B 3.7-60 Amendment No. 116 12/12/07 I

CREACUS B 3.7.11 BASES (continued)

APPLICABILITY In MODES 1, 2, 3, 4, 5, and 6, tttd durin movement of

+rradiaeed fuel assemblies n containment, and during movement of fuel assemblies in the fuel storage pooil, the CREACUS must be OPERABLE to ensure that the CRE will remain habitable during and following a DBA.

EThe term fuel assembly includes irradiated fuel, non-

adiated fuel, and the dummy, fuel assembly.

In MODES 5 and 6, the CREACUS is required to cope with the release from a rupture of a waste gas tank.

During movement of irradiated fuel assemblies, the CREACUS must be OPERABLE to cope with the release from a fuel handling accident involving handling irradiated fuel.

ACTIONS ACTION statements are modified by two NOTES. NOTE 1isays:

"The provisions of LCO 3.0.4 are not applicable when entering MODES 5, 6, or defueled configuration."

Specification 3.0.4 establishes that entry into an operational mode or other specified condition shall not be made unless the conditions of the LCO are met.

Applicability statement "During movement of irradiated fuel asse bIie:: 1rn'........c duri nggT o_ e nt of fu eI n a n e l'...........i:"n" asem- i~es in ýthe f~uel tora e 1"ensures the OPERABILITY of both CREACUS trains prior to the start of movement of irroadit-eud fuel assemblies.

NOTE 2 says: "Each Unit shall enter applicable ACTIONS separately." CREACUS is a shared system between Unit 2 and Unit 3. LCO doesn't address the operational situation when the Units are in different operational MODES. Without this NOTE it may not be clear what ACTIONS should be taken.

(continued)

SAN ONOFRE--UNIT 3 B 3.7-61 Amendment No. 117 12/12/87

CREACUS B 3.7.11 BASES (continued)

ACTIONS A.1 (continued)

With one CREACUS train inoperable, for reasons other than an inoperable CRE boundary, action must be taken to restore OPERABLE status within 14 days. The 14 day AOT is based on a probabilistic risk assessment that does not require administrative controls to be implemented when a CREACUS train is taken out of service. In this Condition, the remaining OPERABLE CREACUS train is adequate to perform the CRE occupant protection function.

However, the overall reliability is reduced because a failure in the OPERABLE CREACUS train could result in loss of CREACUS function. The 14 day Completion Time is based on the low probability of a DBA occurring during this time period, and the ability of the remaining train to provide the required capability.

B.1, B.2 and B.3 If the unfiltered inleakage of potentially contaminated air past the CRE boundary and into the CRE can result in CRE occupant radiological dose greater than the calculated dose of the licensing basis analyses of DBA consequences (allowed to be up to 5 rem TEDE), or inadequate protection of CRE occupants from hazardous chemicals or smoke, the CRE boundary is inoperable. Actions must be taken to restore an OPERABLE CRE boundary within 90 days.

(continued)

SAN ONOFRE--UNIT 3 B 3.7-62 Amendment No. 117 12/12/07

CREACUS B 3.7.11 BASES (continued)

ACTIONS During the period that the CRE boundary is considered (continued) inoperable, action must be initiated to implement mitigating actions to lessen the effect on CRE occupants from the potential hazards of a radiological or chemical event or a challenge from smoke. Actions must be taken within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to verify that in the event of a DBA, the mitigating actions will ensure that CRE occupant radiological exposures will not exceed the calculated dose of the licensing basis analyses of DBA consequences, and that CRE occupants are protected from hazardous chemicals and smoke. These mitigating actions (i.e., actions that are taken to offset--

the consequences of the inoperable CRE boundary) should be preplanned for implementation upon entry into the condition, regardless of whether entry is intentional or unintentional.

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the low probability of a DBA occurring during this time period, and the use of mitigating actions. The 90 day Completion Time is reasonable based on the determination that the mitigating actions will ensure protection of CRE occupants within analyzed limits while limiting the probability that CRE occupants will have to implement protective measures that may adversely affect their ability to control the reactor and maintain it in a safe shutdown condition in the event of a DBA. In addition, the 90 day Completion Time is a reasonable time to diagnose, plan and possibly repair, and test most problems with the CRE boundary.

C.1 and C.2 In MODES 1, 2, 3, or 4, if the inoperable CREACUS or the CRE boundary cannot be restored to OPERABLE status within the required Completion Time, the unit must be placed in a MODE that minimizes the accident risk. To achieve this status, the unit must be placed in at least MODE 3 withi.n 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

(continued)

SAN ONOFRE--UNIT 3 B 3.7-63 Amendment No. 200 12/12/07 1

CREACUS B 3.7.11 BASES (continued)

ACTIONS D.I, D.2.1, D.2.2, an D.2.3 (continued)

In MODE 5 or 6, or during movement of -irad+at.. fuel semlles n the ue ýsora eoo i Required c ion A.1 cannot bcompleted within the required Completion Time, the OPERABLE CREACUS train must be immediately placed in the emergency mode of operation. This action ensures that the remaining train is OPERABLE, that no failures preventing automatic actuation will occur, and that any active failure Will be readily detected.

An alternative to Required Action D.1 is to immediately suspend activities that could result in a release of radioactivity that might require isolation of the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel assemblies to a safe position.

E.1, E.2, anqE.3 When in MODE 5 or 6, or during movement of -rrftdiated fuel inopera eor with one or more CGREGUS trains inoperable due to an inoperable CRE boundary, action must be taken immediately to suspend activities that could result in a release of radioactivity that might enter the CRE. This places the unit in a condition that minimizes the accident risk. This does not preclude the movement of fuel to a safe position.

F._ 1 If both CREACUS trains are inoperable in MODE 1, 2, 3, or 4 for reasons other than an inoperable CRE boundary (i.e.,

Condition B), the CREACUS may not be capable of performing the intended function and the unit is in a condition outside the accident analyses. Therefore, LCO 3.0.3 must be entered immediately.

(continued)

SAN ONOFRE--UNIT 3 B 3.7-64 Amendment No.200 +2+a LoI 7

CREACUS B 3.7.11 BASES (continued)

SURVEILLANCE SR 3.7.11.1 REQUIREMENTS Standby systems should be checked periodically to ensure that they function properly. Since the environment and normal operating conditions on this system are not severe, testing each train once every month provides an adequate check on this system.

Cumulative operation of the system for at least 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months over a 31 day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filtes. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months time frame is based on a conservative engineering evaluation which calculated the time required to evaporate the moisture contained in the air trapped inside the CREACUS duct upstream of charcoal beds. The 31 day Frequency is based on the known reliability of the equipment, and the two train redundancy available.

SR 3.7.11.2 This SR verifies that the required CREACUS testing is performed in accordance with the Ventilation Filter Testing Program (VFTP). The CREACUS filter tests are based on Regulatory Guide 1.52 (Ref. 5). The VFTP includes testing HEPA filter performance, charcoal adsorber efficiency, minimum system flow rate, and the physical properties of theactivated charcoal (general use and following specific operations). Specific test Frequencies and additional information are discussed in detail in the VFTP.

The filtration efficiency only apply to the emergency recirculation air conditioning units E418 and E419.

Therefore, testing for filtration efficiency is not required for the emergency ventilation supply units A206 and A207.

However, the specified air flow from the emergency ventilation units is required during the filtration efficiency testing of the emergency recirculation air conditioning units. Also, the air flow requirements which are specified in the VFTP apply to the emergency ventilation and emergency air conditioning units.

(continued)

SAN ONOFRE--UNIT 3 B 3.7-65 Amendment No. 200 12/12/07

CREACUS B 3.7.11 BASES (continued)

SURVEILLANCE SR 3.7.11.3 REQUIREMENTS (continued)

This SR verifies that each CREACUS train starts and operates on an acutual or simulated actuation signal. The Frequency of 24 months is based on industry operating experience and is consistent with the typical refueling cycle.

SR 3.7.11.4 This SR verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.

The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5'rem 'TEDE and the CRE occupants are protected from hazardous chemicals and smoke.

This SR verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air inleakage is greater than the assumed flow rate, Condition B must be entered. Required Action B.3 allows time to-restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 6) which endorses, with exceptions, NEI 99-03, Section (continued)

SAN ONOFRE--UNIT 3 B 3.7-66 Amendment No. 200 12/12/07 1

CREACUS B 3.7.11 BASES (continued)

SURVEILLANCE SR 3.7.11.4 REQUIREMENTS (continued) 8.4 and Appendix F (Ref. 7). These compensatory measures may also be used as mitigating actions as required by Required Action B.2. Temporary analytical methods may also be used as compensatory measures to restore OPERABILITY (Ref. 8). Options for restoring the CRE boundary to OPERABLE status include changing the licensing basis DBA consequence analysis, repairing the CRE boundary, or a combination of. these actions. Depending upon the nature of the problem and the corrective action, a full scope inleakage test may not be necessary to establish that the CRE boundary has been restored to OPERABLE status.

REFERENCES 1. UFSAR, Section 9.4.

2. UFSAR, Chapter 15.

3. UFSAR, Section 6.4.

4. UFSAR, Section 9.5.

5. Regulatory Guide 1.52 (Rev. 2).

6. Regulatory Guide 1.196.

7. NEI 99-03, "Control Room Habitability Assessment,"

June 2001.

8. Letter from Eric J. Leeds (NRC) to James W. Davis (NEI) dated January 30, 2004, "NEI Draft White Paper, Use of Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability." (ADAMS Accession No. ML040300694).

(conti nued)

SAN ONOFRE--UNIT 3 B 3.7-67 Amendment No. 200 12/12/07 1

Fuel Storage Pool Water Level B 3.7.16 B 3.7 PLANT SYSTEMS B 3.7.16 Fuel Storage Pool Water Level BASES BACKGROUND The minimum water level in the fuel storage pool meets the assumptions of iodine decontamination factors following a fuel handling accident. The specified water level shields and minimizes the general area dose when the storage racks are filled to their maximum capacity. The water also provides shielding during the movement of spent fuel.

A general description of the fuel storage pool design is given in the UFSAR, Section 9.1.2, Reference 1, and the Spent Fuel Pool Cooling and Cleanup System is given in the UFSAR, Section 9.1.3 (Ref. 2). The assumptions of the fuel handling accident are given in the UFSAR, Section 15.7.3.4 and 15.7.3.6 (Ref. 3 and Ref. 6).

APPLICABLE The minimum water level in the fuel storage pool meets the SAFETY ANALYSES assumptions of the fuel handling accident described in Regulatory Guide 1.25 (Ref. 4). The resultant 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thyroid dose to a person at the exclusion area boundary is a small fraction of the 10 CFR 100 (Ref. 5) limits.

According to Reference 4, there is 23 ft of water between the top of the damaged fuel bundle and the fuel pool surface for a fuel handling accident. With this 23 ft of water, the assumptions of Reference 4 can be. used directly. In practice, this LCO preserves this assumption for the bulk of the fuel in the storage racks. In the case of a single bundle, dropped and lying horizontally on top of the spent fuel racks, there would be < 23 ft of water above the top of the bundle.

However, when the potential of a dropped fuel assembly exists (which is when fuel is being moved) a water level is maintained that would ensure that there would be >23 feet above the fuel assembly laying on top of the racks. This increased water level is required by LCO 3.9.6 when the fuel storage pool is connected to the refueling cavity and by station procedures whenever fuel is being moved.

(conti nued)

SAN ONOFRE--UNIT 3 B 3.7-68 Amendment No. 116 10/13/98

Fuel Storage Pool Water Level B 3.7.16 BASES (continued)

APPLICABLE The fuel storage pool water level satisfies Criterion 3 of SAFETY ANALYSES the NRC Policy Statement.

(continued)

LCO The specified water level preserv'es the assumptions of the fuel.handling accident analysis (Ref. 3). As such, it is the minimum required for fuel storage and movement within the fuel storage pool.

APPLICABILITY This LCO applies durinn movement fue1--el, of non-irr1adiatedfue iradiated fuel assemblie (e., irradiated a te dummy fuel assembly) -n e ue storage pool since the potential for a release of fission products exists.

ACTIONS A.1 Required Action A.1 is modified by a Note indicating that LCO 3.0.3 does not apply.

When the initial conditions for an accident cannot be met, steps should be taken to preclude the accident from occurring. When the fuel storage pool water level is lower than the required level, the movement of irradiated fuel assemblies in the fuel storage pool is immediately suspended. This effectively precludes a spent fuel handling accident from occurring. This does not preclude moving a fuel assembly to a safe position.

If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODES 1, 2, 3, and 4, the fuel movement is independent of reactor operations.

Therefore, in either case, inability to suspend movement of irradiate fuel assemblies is not sufficient reason to require a reactor shutdown.

(continued)

SAN ONOFRE--UNIT 3 B 3.7-69 Amendment No. 116 ,,/13/98

Fuel Storage Pool Water Level B 3.7.16 BASES (continued)

SURVEILLANCE SR 3.7.16.1 REQUIREMENTS This SR verifies sufficient fuel storage pool water is available in the event of a fuel handling accident. The water level in the fuel storage pool must be checked periodically. The 7 day Frequency is.appropriate because the volume in the pool is normally stable. Water level changes are controlled by unit procedures and are acceptable, based on operating experience.

During refueling operations, the level in the fuel storage pool is at equilibrium with that of the refueling canal, and the level in the refueling canal is checked daily in accordance with LCO 3.9.6, "Refueling Water Level."

REFERENCES 1. UFSAR, Section 9.1.2.

2. UFSAR, Section 9.1.3.

3. UFSAR, Section 15.7.3.4.

4. Regulatory Guide 1.25

5. 10 CFR 100.11.

6. UFSAR, Section 15.7.3.6 SAN ONOFRE--UNIT 3 B 3.7-70 Amendment No. 116 10/13/98

AC Sources-Shutdown B 3.8.2 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.2 AC Sources-Shutdown BASES BACKGROUND A description of the AC sources is provided in the Bases for LCO 3.8.1, "AC Sources-Operating."

APPLICABLE The OPERABILITY of the minimum AC sources during MODES 5 SAFETY ANALYSES and 6 ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods;

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

c. Adequate AC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident.

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required. The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, 3, and 4 have no specific analyses in MODES 5 and 6. Worst case bounding events are deemed not credible in MODES 5 and 6 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.

During MODES 1, 2, 3, and 4, various deviations from the analysis assumptions and design requirements are allowed within the Required Actions. This allowance is in recognition that certain testing and maintenance activities (continued)

SAN ONOFRE--UNIT 3 B 3.8-30 Amendment No. 116

AC Sources- Shutdown B 3.8.2 BASES (continued)

APPLICABLE must be conducted provided an acceptable level of risk is SAFETY ANALYSES not exceeded. During MODES 5 and 6, performance of a (continued) significant number of required testing and maintenance activities is also required. In MODES 5 and 6, the activities are generally planned and administratively controlled. Relaxations from MODE 1, 2, 3, and 4 LCO requirements are acceptable during shutdown modes based on:

a. The fact that time in an outage is limited. This is a risk prudent goal as well as a utility economic consideration.

b. Requiring appropriate compensatory measures for certain conditions. These may include administrative controls, reliance on systems that do not necessarily meet typical design requirements applied to systems credited in operating MODE analyses, or both.

c. Prudent utility consideration of the risk associated with 'Multiple activities that could affect multiple systems.

d. Maintaining, to the extent practical, the ability to perform required function's (even if not meeting MODE 1, 2, 3, and 4 OPERABILITY requirements) with systems assumed to function during an event.

In the event of an accident during shutdown, this LCO ensures the capability to support systems necessary to avoid immediate difficulty, assuming either a loss of all offsite power or a loss of all onsite diesel generator (DG) power.

The AC sources satisfy Criterion 3 of the NRC Policy Statement.

LCO One offsite circuit capable of supplying the onsite Class 1E power distribution subsystem(s) of LCO 3.8.10, "Distribution Systems-Shutdown," ensures that all required loads are powered from offsite power. An OPERABLE DG, associated with a distribution system train required to be OPERABLE by LCO 3.8.10, ensures a diverse power source is available to provide electrical power support, assuming a loss of the offsite circuit. Together, OPERABILITY of the required offsite circuit and DG ensures the availability of (continued)

SAN ONOFRE--UNIT 3 B 3.8-31 Amendment No. 116

AC Sources- Shutdown B 3.8.2 BASES (continued)

LCO sufficient AC sources to operate the unit in a safe manner (continued) and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

The qualified offsite circuit must be capable of maintaining rated frequency and voltage, and accepting required loads during an accident, while connected to the Engineered Safety Feature (ESF) bus(es). Qualified offsite circuits are those that are described in the UFSAR and are part of the licensing basis for the unit.

One source of offsite power (Offsite circuit #1) for each unit is normally provided through Reserve Auxiliary Transformers XR1 and XR2 for the specific unit. XR1 feeds one 4.16 KV ESF bus (Train A) A04 and XR2 feeds the other 4.16 KV ESF bus (Train B) A06 of the onsite Class 1E AC distribution system for each unit. The second source of offsite power (Offsite circuit #2) is provided by the other unit's Reserve Auxiliary Transformers XR1 and XR2 through the train oriented 4.16 KV ESF bus crossties between the two units. In addition, an alternate offsite source of power for each unit would be, with the unit's main generator isophase bus links removed., each unit's Auxiliary Transformer XU1.

The DG must be capable of starting, accelerating to rated speed and voltage, connecting to its respective ESF bus on detection of bus undervoltage, and accepting required loads.

This sequence must be accomplished within 10 seconds. The DG must be capable of accepting required loads within the assumed loading sequence intervals, and must continue to operate until offsite power can be restored to the ESF buses. These capabilities are required to be met from a variety of initial conditions such as DG in standby with the engine hot, DG in standby at ambient conditions, and DG operating in a parallel test mode.

Proper sequencing of loads, including tripping of nonessential loads, is a required function for DG OPERABILITY. Load sequencing is accomplished through the programmed time load sequence interval utilizing individual timing relays for each load in lieu of a single "automatic load sequencer."

(continued)

SAN ONOFRE--UNIT 3 B 3.8-32 Amendment No. 116

AC Sources- Shutdown B 3.8.2 BASES (continued)

LCO It is acceptable for trains to be cross tied during shutdown (continued) conditions, allowing a single offsite power circuit to supply all required trains.

APPLICABILITY The AC sources required to be OPERABLE in MODES 5 and 6, &-r-during movement of irradiated fuel assemblies within cn-gtanment and dri ngmovement-of fTuel assemblies in the Zfuel st~orage polrvd- asurne t-hat:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies in

the core;

b. Systems needed to mitigate a fuel handling accident are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The AC power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.1.

The term fuel assembly includes irradiated fuel, non-rradiated fuel, and the dummy fuel assembly.

ACTIONS A. 1 An offsite circuit would be considered inoperable if it were not available to the required ESF train. Although one train is required by LCO 3.8.10 the remaining train with offsite power available may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and/or fuel movement. By the allowance of the option to declare inoperable the required features associated with the inoperable offsite circuit, appropriate restrictions will be implemented in accordance with the affected required features LCO's ACTIONS.

(continued)

SAN ONOFRE--UNIT 3 B 3.8-33 Amendment No. 116

AC Sources- Shutdown B 3.8.2 BASES (continued)

ACTIONS 2.1. A.2.2, A.2.3, A.2.4 A.'. B.1. B.2, B.3, B.4, and B3, (continued)

With the offsite circuit not available to the required train (Condition A), the option exists to declare all required features inoperable. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made. With the required DG inoperable (Condition B), the minimum required diversity of AC power sources is not available. It 's therefore, required to suspend CORE ALTERATIONS spenI¢ movement of fue assmbles1 1,ntainment,Z

111 11lif mue as e s 1 the fuel sto age~g 001, n u ndopra ions1 0 vi g civity a ions at could result in loss of required SDM (Mode 5)

or boron concentration (Mode 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition.

These actions minimize the probability or the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the unit safety systems.

Notwithstanding performance of the conservative Required Actions, the unit is still without sufficient AC power sources to operate in a safe manner. Therefore, action must be initiated to restore the minimum required AC power

sources and continue until the LCO requirements are restored.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be without sufficient power.

(continued)

SAN ONOFRE--UNIT 3 B 3.8-34 Amendment No. 1-1-6,166 12/29o/0n

AC Sources- Shutdown B 3.8.2 BASES (continued)

ACTIONS ,? *1, A.2.2, A.2.3. A.2.4A.2.5 B.1 B.2, B.3, B.4 and WB.5 o tinued)

Pursuant to LCO 3.0.6, the Distribution System's (LCO 3.8.10) ACTIONS are not entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A are modified by a Note to indicate that when Condition A is entered with no AC power to one ESF bus, the ACTIONS for LCO 3.8.10 must be immediately entered. This Note allows Condition A to provide requirements for the loss of the offsite circuit, whether or not a train is de-energ.ized. LCO 3.8.10 provides the appropriate restrictions for the situation involving a de-energized train.

SURVEILLANCE SR 3.8.2.1 REQUI REMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, 3, and 4. SR 3.8.1.17 is not required to be met because the required OPERABLE DG is not required to undergo periods of being.synchronized to the offsite circuit. SR 3.8.1.20 is excepted because starting independence is not required with DG(s) that are not required to be OPERABLE.

This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DG from being paralleled with the offsite power network or otherwise rendered inoperable. With limited AC Sources available, a single event could unnecessarily compromise both the required circuit and the DG. The SRs listed in the Note are not required to be performed for the OPERABLE AC sources during Modes 5 and 6, e-nd during movement of iradiated fuel sources are presumed to be able to meet these surveillances.

If it is discovered (through'analysis or unplanned events, for example) that the required AC sources could not meet these surveillances, then the equipment must be considered inoperable. Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

REFERENCES 1. UFSAR, Chapter 15.

SAN ONOFRE--UNIT 3 B 3.8-35 Amendment No. 4-1--,166 12/20**9

DC Sources- Shutdown B 3.8.5 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.5 DC Sources -Shutdown BAS ES BACKGROUND A description of the DC sources is provided in the Bases for LCO 3.8.4, "DC Sources - Operating.' When TS 3.8.5 applies, there are two exceptions to what is described in the Bases for LCO 3.8.4:

1. One or both train(s) of the DC subsystem buses may be cross-tied to an 1800 amp-hour rated battery. This alignment allows both subsystems to remain OPERABLE. There is no time limit to the duration DC subsystem buses may be cross-tied with the-unit shutdown.

2. With same train DC buses cross connected, an OPERABLE charger or chargers with a combined rated capacity.

greater than or equal to 300 Amps is required. A "required battery charger" is one of the following:

S the "dedicated charger" aligned to its respective DC bus S the "swing battery charger" aligned to the respective DC bus 0 one "dedicated charger" aligned to cross-tied DC buses, or S the "swing battery charger" aligned to cross-tied DC buses.

Note: It is acceptable to have the swing charger and one dedicated charger aligned to cross-connected buses.

APPLICABLE The initial conditions of Design Basis Accident (DBA) and SAFETY ANALYSES transient analyses in the UFSAR, Chapter 6 (Ref. 1) and Chapter 15 (Ref. 2), assume that Engineered Safety Feature (ESF) systems are OPERABLE. The DC electrical power system provides normal and emergency DC electrical power for the DGs, emergency auxiliaries, and control and switching during all MODES of operation.

The OPERABILITY of the DC subsystems is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum DC electrical power sources during MODES 5 anddi 6,fuelr mvmeto aseb ,2jj ein- uontaenT anlssTn 'moemento f fuel_)

a. The unit can be maintained in the shutdown or refueling condition for extended periods; (continued)

SAN ONOFRE--UNIT 3 B 3.8-56 Amendment No. 116 03/113o/19

DC Sources- Shutdown B 3.8.5 BASES APPLICABLE b. Sufficient instrumentation and control capability is SAFETY ANALYSES available for monitoring and maintaining the unit (continued) status; and

c. Adequate DC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident.

The DC sources satisfy Criterion 3 of the NRC Policy Statement.

LCO Each DC electrical power subsystem, consisting of one battery (cross connection allowed), the required battery charger, and the corresponding control equipment and interconnecting cabling supplying power to the associated bus, is required to be OPERABLE o s upport distribution systems required OPERABLE by LCO 3.8.1, "Distribution Systems - Shutdown." This ensures the availability of sufficient DC electrical power sources to maintain the unit in a safe shutdown condition and to mitigate the consequences of postulated events during shutdown (e.g.,

fuel handling accidents).

APPLICABILITY The DC electrical power sources required to be OPERABLE in MODES 5 and 6, e194 during movement of irradiated fuel assemblies within containment, and uring movement of fuel-"

assemblies in the fuel storage pool rov'ide assurance that:t

a. Required features to mitigate a fuel handling accident are available;

b. Required features necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

c. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The DC electrical power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.4.

/The term fuel assembly includes irradiated fuel, non-irradiated fuel, and the dummy fuel assembly.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since irradiated fuel assembl movement can occur in MODE 1, 2, 3, or 4, the ACTIONS have been modified by a NOTE stating that LCO 3.0.3 is not applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, LCO 3.0.3 would not specify (continued)

SAN ONOFRE--UNIT 3 B 3.8-57 Amendment No. 116 n3/3/1#9

DC Sources- Shutdown B 3.8.5 BASES ACTIONS any action. If moving irra'di-adite fuel assemblies while in (continued) MODE 1, 2, 3, or 4, the fuel movement is independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, 2, 3 or 4 would require the unit to be shutdown unnecessarily.

Conditions A and B represent one train with one or two required battery chargers or associated control equipment or cabling inoperable (e.g., the battery voltage limit of SR 3.8.4.1 is not maintained). The ACTIONS provide a tiered response that focuses on returning the battery to the fully charged state and restoring the required charger(s) to OPERABLE status in a reasonable time period.

A.1, A.2. and A.3 (A.3.1 or A.3.2.1 and A.3.2.2)

Condition A is modified by a NOTE identifying that it is only applicable to 1800 amp-hour rated batteries.

Required Action A.1 requires that the battery terminal voltage be restored to greater than or equal to the minimum established float voltage (? 129.0 V) within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This time provides for returning the inoperable charger to' OPERABLE status or providing an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage. Restoring the battery terminal voltage to greater than or equal to minimum established float voltage provides good assurance that, within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , the battery will be restored to its fully charged condition (Required Action A.2) from any discharge that might have occurred due to the charger inoperability.

A discharged battery having terminal voltage of at least the minimum established float voltage indicates that the battery is on the exponential charging current portion (the second part) of its recharge cycle. The time to return a battery to its fully charged state under this:condition is simply a function of the amount of the previous discharge and the recharge characteristic of the battery. Thus, there is good assurance of fully recharging the battery within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , avoiding a shutdown of refueling activities.

If established battery terminal float voltage cannot be restored to greater than or equal to the minimum established float voltage within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and the charger is not operating in the current limiting mode, a faulty charger is indicated. A faulty charger that is incapable of maintaining established battery terminal float voltage does not provide assurance that it can revert to and operate properly in the current limit mode that is necessary during the recovery period following a battery discharge event that the DC system is designed for.

(continued)

SAN ONOFRE--UNIT 3 B 3.8-58 Amendment No. 116 ,3/3/*09

DC Sources- Shutdown B 3.8.5 BASES ACTIONS A.I, A.2, and A.3 (A.3.1 or A.3.2.1 and A.3.2.2) (continued)

The charger operating in the current limit mode in excess of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is an indication that the battery is partially discharged and its capacity margins will be reduced. The time to return the battery to its fully charged condition in this case is a function of the battery charger capacity, the amount of loads on the associated DC system, the amount of the previous discharge, and the recharge characteristic of the battery. The charge time can be extensive, and there is not adequate assurance that it can be fully recharged within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Required Action A.2).

Required Action A.2 requires that the battery float current be verified as less than or equal to 21.50 amps. This indicates that, if the battery had been discharged as the result of the inoperable battery charger, it is now fully capable to-supply the maximum expected load requirement.

The battery manufacturer certified that at 1.50 amps the battery is at least 98% charged. A 2% capacity margin (correction factor) has been used in the battery sizing calculation (Ref. 3) which ensures that the battery has sufficient capacity to meet the maki'mum expected load demand. If at the expiration of the initial 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months period the battery float current is not less than or equal to 1.50 amps this indicates there may be additional battery problems and the battery must be declared inoperable.

A digital multimeter of high accuracy in an average function mode is required to measure the steady state float charging current (Ref. 4). The multimeter must be capable of measuring the low magnitude of DC current (less than 1.50 amps) and filtering the induced AC noise from the connected inverter. A millivolt shunt located close to the battery terminal provides the battery float charging current signal.

Required Action A.3 (A.3.1 or A.3.2.1 and A.3.2.2) is applicable if an alternate means of restoring battery terminal voltage to greater than or equal to the minimum established float voltage has been used (e.g., balance of plant non-Class 1E spare battery charger).

Required Action A.3.1 limits the, restoration time for the required battery charger to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months if a non-1E charger with a non-lE power source is used. The restoration. time for the battery charger can be extended to 7 days .(required Action A.3.2.2) if the ability to power the spare battery charger from a diesel-backed source has been established within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (Required Action A.3.2.1). All preparations to accomplish the ability to power the spare battery charger must be complete within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The purpose of this (continued)

SAN ONOFRE--UNIT 3 B 3.8-59 Amendment No. 116 03/13/09

DC Sources- Shutdown B 3.8.5 BASES ACTIONS A.Iý A.2. and A.3 (A.3.1 or A.3.2.1 and A.3.2.2) (continued) provision is to facilitate connection of the spare battery charger to a diesel-backed source in : 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months if non-IE power is lost. The 4-hour charger connection time is required because 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after the loss of non-iE power, the battery may not supply the minimum required voltage at the loads. The 7-day completion time reflects a reasonable time to effect restoration of the required battery charger to operable status.

B.I, B.2, and B.3. (B.3.1 or B.3.2.1 and B.3.2.2)

Condition B is modified by a NOTE identifying that it is only applicable to 1260 amp-hour rated batteries.

Required Action B.1 basis is the same as A.1.

Required Action B.2 requires that the battery float current be verified to be less than or equal to 0.75 amp. This indicates that, if the battery had been discharged as the result of the inoperable battery charger, it is now fully capable to supply the maximum expected load requirement.

The battery manufacturer certified that at 0.75 amp the battery is at least 98% charged. A 2% capacity margin (correction factor) has been used in the battery sizing calculation (Ref. 3) which ensures that the battery has sufficient capacity to meet the maximum expected load demand. If at the expiration of the initial '12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months period the battery float current is not less than or equal to 0.75 amp this indicates there may be additional battery problems and the battery must be declared inoperable.

A digital multimeter of high accuracy in an average function mode is required to measure the steady state float charging current (Ref. 4). The multimeter must be capable of measuring the low magnitude of DC current (less than 0.75 amp) and filtering the indicated AC noise from the connected inverter. A millivolt shunt located close to the battery terminal provides the battery float charging current signal.

Required Action B.3 (B.3.1 or B.3.2.1 and B.3.2.2) basis is the same as A.3 (A.3.1 or A.3.2.1 and A.3.2.2).

(continued)

SAN ONOFRE--UNIT 3 B 3.8-59a Amendment No. 127 03/13/09

DC Sources -Shutdown B 3.8.5 BASES ACTIONS C.1 (continued)

With the required DC electrical power subsystem battery charger or associated control equipment or cabling outside the allowances of the Required Actions for Condition A or B, sufficient capacity to supply the maximum expected load requirement is not assured and the associated DC battery must be declared inoperable immediately.

D.1, or D.2.1, D.2.2, D.2.3, D.2.4, and D.2.5 Condition D represents one DC electrical power subsystem inoperable for reasons other than Condition A or B including when a battery is inoperable (Condition C). The ACTIONS provide a tiered response allowing the option to declare required features inoperable immediately with the associated DC power source(s) inoperable.

If two trains are required per LCO 3.8.10, the remaining train with DC power available may be capable of supporting sufficient systems to allow continuation of CORE ALTERATIONS and fuel movement. By allowing the option to declare required features inoperable with the associated DC power source(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCO ACTIONS. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservatiye ctions is made (i.e., to suspend CORE ALTERA I05,.fn-d-sý`spe*n-- ovement of additions The Required Action to suspend positive reactivity additions does not preclude actions to maintain or increase reactor vessel inventory, provided the required SDM is maintained.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition.

These actions minimize probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required DC electrical power subsystems and to continue this action until restoration is accomplished in order to provide the necessary DC electrical power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required DC electrical power subsystems should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be without sufficient power.

(continued)

SAN ONOFRE--UNIT 3 B 3.8-59b Amendment No. 127 03/3/09

DC Sources- Shutdown B 3.8.5 BASES (continued)

SURVEILLANCE SR 3.8.5.1 REQUIREMENTS SR 3.8.5.1 states that Surveillances required by SR 3.8.4.1 through SR 3.8.4.34 are applicable in these MODES. See the corresponding Bases for LCO 3.8.4 for a discussion of each SR.

This SR is modified by a NOTE. The reason for the NOTE is to preclude requiring the OPERABLE DC sources from being discharged below their capability to provide the required power supply or otherwise rendered inoperable during the performance of SRs. It is the intent that these SRs must still be capable of being met, but actual performance is not required.

REFERENCES 1. UFSAR, Chapter 6.

2. UFSAR, Chapter 15.

3. SCE Calculation E4C-017.

4. Response to Request for Additional Information on Battery and DC Sources Upgrades dated November 14,.2008.

(continued)

SAN ONOFRE--UNIT 3 B 3.8-59c Amendment No. 127 03/13/09

Inverters- Shutdown B 3.8.8 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.8 Inverters -Shutdown BASES BACKGROUND A description of the inverters is provided in the Bases for LCO 3.8.7, "Inverters-Operating."

APPLICABLE The initial conditions of Design Basis Accident (DBA) and SAFETY ANALYSES transient analyses in the UFSAR, Chapter 6 (Ref. 1) and Chapter 15 (Ref. 2), assume Engineered Safety Feature systems are OPERABLE. The DC to AC inverters are designed to provide the required capacity, capability, redundancy, and reliability to ensure the availability of necessary power to the Reactor Protective System and Engineered Safety Features Actuation System instrumentation and controls so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.

The OPERABILITY of the inverters is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum inverters to each AC vital bus during MODES 5 and 6 ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods;

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

c. Adequate power is available to mitigate events postulated during shutdown, such as a fuel handling accident.

The inverters were previously identified as part of the distribution system and, as such, satisfy Criterion 3 of the NRC Policy Statement.

(continued)

SAN ONOFRE--UNIT 3 B 3.8-71 Amendment No. 116

Inverters - Shutdown B 3.8.8 BASES (continued)

LCO The required inverters ensure the availability of electrical power for the instrumentation for systems required to shut down the reactor and maintain it in a safe condition after an anticipated operational occurrence or a postulated DBA.

The battery powered inverters provide uninterruptible supply of AC electrical power to the AC vital buses even if the 4.16 kV safety buses are de-energized. OPERABILITY of at least two of the four inverters and the associated vital buses is required. This ensures the availability of sufficient inverter power sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents).

APPLICABILITY The inverters required to be OPERABLE in MODES 5 and 6, frnd

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core;

b. Systems needed to mitigate a fuel handling accident are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

Inverter requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.7.

The term fuel assemblyiclds raiated fuel, non-irrdaed fuelu, and'the dummy fuel assembly.

ACTIONS A.1, A.2.1, A.2.2, A.2.3, A.2.4, andA5 If two trains of 120 VAC Vital Buses are required by LCO 3.8.10, "Distribution Systems-Shutdown," the remaining OPERABLE inverters may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS, fuel movement, and operations with a potential for positive (continued)

SAN ONOFRE--UNIT 3 B 3.8-72 Amendment No. 116

inverters- Shutdown B 3.8.8 BASES (continued)

ACTIONS Aml, A.2.1, A.2.2, A.2.3, A.2.4, and .2.5 (continued) reactivity additions that could result in loss of required SDM (Mode 5) or boron concentration (Mode 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM. By the allowance of the option to declare required features inoperable with the associated inverter(s) inoperable, appropriate restrictions wil.l be implemented in accordance with the affected required features LCOs' Required ACTIONS. In many instances, this option may involve undesired administrative efforts.

Therefore, the allowance for sufficiently conservative actions is made (i.e., to suspend CORE ALTERATIONS, and "el soaepoen upn oeain nvolving positive reac iv tns).

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition.

These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required inverters and to continue this action until restoration is accomplished in order to provide the necessary inverter power to the unit safety systems.

Notwithstanding performance of the above conservative Required Actions, the unit is still without sufficient.AC vital power sources to operate in a safe manner. Therefore, action must be initiated to restore the minimum required AC vital power source and continue until the LCO requirements are restored.

(continued)

SAN ONOFRE--UNIT 3 B 3.8-73 Amendment No. +-1-6,166 12-/20*9

Inverters- Shutdown B 3.8.8 BASES (continued)

ACTIONS A.1, A.2.1, A.2.2, A.2.3., A.2.4, and* .5 (continued)

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required inverters should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power or powered from a constant voltage source transformer.

SURVEILLANCE SR 3.8.8.1 REQUIREMENTS This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and AC vital buses energized from the inverter. The verification of proper voltage output ensures that the required power is readily available for the instrumentation connected to the AC vital buses. The. 7 day Frequency takes into account the redundant capability of the inverters and other indications available in the control room that alert the operator to inverter malfunctions.

REFERENCES 1. UFSAR, Chapter 6.

2. UFSAR, Chapter 15.

SAN ONOFRE--UNIT 3 B 3.8-74 Amendment No. -I-1-6,166 12/20/00 I

Distribution Systems -Shutdown B 3.8.10 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.10 Distribution Systems -Shutdown BASES BACKGROUND A description of the AC, DC, and AC vital bus electrical power distribution systems is provided in the Bases for LCO 3.8.9, "Distribution Systems(Operating" and the Bases for LCO 3.8.5, "DC Sources - Shutdown."

APPLICABLE The initial conditions of Design Basis Accident and SAFETY ANALYSES transient analyses in the UFSAR, Chapter 6 (Ref. 1) and Chapter 15 (Ref. 2), assume Engineered Safety Feature (ESF) systems are OPERABLE. The AC, DC, and AC vital bus electrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded.

The OPERABILITY of the AC, and DC, electrical power distribution systems and AC vital buses is consistent with the initial assumptions of the accident analyses and the requirements for the supported systems' OPERABILITY.

The OPERABILITY of the minimum AC, and DC electrical power distribution systems, and AC vital buses during MODES 5 and 6 ensures that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods;

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status; and

c. Adequate power is provided to mitigate events postulated during shutdown, such as a fuel handling accident.

The AC and DC electrical power distribution systems satisfy Criterion 3 of the NRC Policy Statement.

(continued)

SAN ONOFRE--UNIT 3 B 3.8-84 Amendment No. 116 03/13/09

Distribution Systems -Shutdown B 3.8.10 BASES (continued)

LCO Various combinations of electrical distribution systems, equipment, and components are required OPERABLE by other LCOs, depending on the specific unit condition. Implicit in those requirements is the required OPERABILITY of necessary support required features. This LCO explicitly requires energization of the portions of the electrical distribution system necessary to support OPERABILITY of required systems, equipment and components(all specifically addressed. in each LCO and implicitly required via the definition of OPERABILITY.

Maintaining theseportions of the distribution system energized ensures the availability of sufficient power to operate the unit i-n a safe manner to mitigate the consequences of postulated events during shutdown (e.g.,

fuel handling accidents).

APPLICABILITY The AC and DC electrical power distribution systems required to be OPERABLE in MODES 5 and 6*eftd during wovement of

ovemýent of fuel ass m es in the fuel storage pool ovide

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel in the core;

b. Systems needed to mitigate a fuel handling accident are available;

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available; and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition and refueling condition.

The AC, and DC electrical power distribution systems, and AC vital buses requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.9.

(continued)

SAN ONOFRE--UNIT 3 B 3.8-85 Amendment No. 116 03/13/,9

Distribution Systems- Shutdown B 3.8.10 BASES (continued)

ACTIONS A.1. A.2.1, A.2.2, A.2.3. A.2.4, A.2.5, andbA.2.6ý Although redundant required features may require redundant trains of electrical power distribution subsystems to be OPERABLE, one OPERABLE distribution system may be capable of supporting sufficient required features to allow continuation of CORE ALTERATIONS and fuel movement. By allowing the option to declare required features associated with an inoperable distribution subsystem inoperable, appropriate restrictions are implemented in accordance with the affected distribution systems LCO's Required Actions. In many instances, this option may involve undesired administrative efforts. Therefore, the allowance for sufficiently conservative actions is made (i.e., to-suspend operat~ions involving posi i e r a vity a itions that could result in loss of required SDM (Mode 5) or boron concentration (Mode 6)). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation.

Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities shall not preclude completion of actions to establish a safe conservative condition.

These actions minimize the probability of the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC and DC electrical power distribution systems and to continue this action until restoration is accomplished in order.to provide the necessary power to the unit safety systems.

Notwithstanding performance of the above conservative Required Actions, a required shutdown cooling (SDC) system may be inoperable. In this case, these Required Actions of Condition A do not adequately address the concerns relating to coolant circulation and heat removal. Pursuant to LCO 3.0.6, the SDC ACTIONS would not be entered.

(continued)

SAN ONOFRE--UNIT 3 B 3.8-86 Amendment No. 116 0 3 //

13/

Distribution Systems-Shutdown B 3.8.10 BASES (continued)

ACTIONS A.1, A.2.1, A.2.2, A.2.3, A.2.4, A.2.5, and*A.2.6T (continued)D Therefore, the Required Actions of Condition A direct declaring SDC inoperable, which results in taking the appropriate SDC actions.

The Completion Time of immediately is consistent with the required times for actions requiring promptattention. The restoration of the required distribution systems should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power.

SURVEILLANCE SR 3.8.10.1 REQUIREMENTS This Surveillance verifies that the AC, DC, and AC vital bus electrical power distribution system is functioning properly, with all the required buses energized. The verification of proper voltage availability on the buses ensures that the required power is readily available for motive as well as control functions for critical system loads connected to these buses. The 7-day frequency takes into account the redundant capability of the electrical power distribution systems and other indications available in the control room that alert the operator to system malfunctions.

REFERENCES 1. UFSAR, Chapter 6.

2. UFSAR, Chapter 15.

(conti nued)

SAN ONOFRE--UNIT 3 B 3.8-87 Amendment No. 116 03/13/09

Containment Penetrations B 3.9.3 B 3.9 REFUELING OPERATIONS B 3.9.3. Containment Penetrations BASES BACKGROUND During CORE ALTERATIONS or movement of fuel assemblies within containment with irradiated fuel in containment, a release of fission product radioactivity within the containment will be restricted from escaping to the environment when the LCO requirements are met. In MODES 1, 2, 3, and 4, this is accomplished by maintaining containment OPERABLE as described in LCO 3.6.1, "Containment." In MODE 6, the potential for containment pressurization as a result of an accident is not likely; therefore, requirements to isolate the containment from the outside atmosphere can be less stringent. The LCO requirements are referred to as "containment closure" rather than "containment OPERABILITY."

Containment closure means that all potential escape paths are closed or capable of being closed. Since there is no potential for containment pressurization, the Appendix J, Option B leakage criteria and tests are not required.

The containment serves to contain fission product radioactivity that may be released from the reactor core following an accident, such that offsite radiation exposures are maintained well within the requirements of 10 CFR 100.

Additionally, the containment structure provides radiation shielding from the fission products that may be present in the containment atmosphere following accident conditions.

The containment equipment hatch, which is part of the containment pressure boundary, provides a means for moving large equipment and components into and out of containment.

During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, the equipment hatch must be held in place by at least four bolts. Good engineering practice dictates that the bolts required by this LCO be approximately equally spaced.

The containment air locks, which are also part of the containment pressure boundary, provide a means for personnel access during MODES 1, 2, 3, and 4 operation in accordance with LCO 3.6.2, "Containment Air Locks." Each air lock has a door at both ends. The doors are normally interlocked to prevent simultaneous opening when containment OPERABILITY is required. During periods of shutdown when containment (continued)

SAN ONOFRE--UNIT 3 B 3.9-9 Amendment No. 116 12/98

Containment Penetrations B 3.9.3 BASES (continued)

BACKGROUND closure is not required, the door interlock mechanism may be (continued) disabled, allowing both doors of an air lock to remain open for extended periods when frequent containment entry is necessary. During CORE ALTERATIONS or movement of irradiated fuel assemblies within containment, containment closure is required; therefore, the door interlock mechanism may remain disabled, but one air lock door must always remain closed or operable. Operability of the containment ersonnel airlock door requires that the door is capable of eing closed; that the door is unblocked and no cables or hoses are being run through the airlock; and that a designated individual is continuously available to close the airlock door. This individual must be stationed at the outer airlock door.

The use of temporary ramps for equipment access through the containment personnel air lock doors is acceptable during CORE ALTERATIONS or moving of irradiated fuel within containment. These ramps do not impede closure of the containment personnel airlock doors as the ramps are quickly removed by the designated individual stationed at the outer door. Removal of the ramps is a normal function of door closure, and the ability of plant personnel to close the personnel airlock, if needed, is not compromised by the ramps. Similarly, door seal covers may be used, provided they are removed prior to air lock-door closure.

Except the systems that are closed inside of containment, systems conducting a fluid in and/or out of containment can also satisfy LCO 3.9.3 in either of the following configurations:

a. Systems containing devices inside containment which would preclude free air flow from containment such as self-closing quick disconnects, relief valves venting to containment, check valve(s), five foot water seal (periodic seal verification required), reciprocating pump, pipe cap, or any other equivalent device which would preclude free air flow out of containment.

b. Systems containing devices outside containment which would preclude free air flow from containment such as a reciprocating air compressor, compressed gas cylinder, or any of the devices listed in "a" above..

(continued)

SAN ONOFRE--UNIT 3 B 3.9-10 Amendment No. 4-+6-,184

Containment Penetrations B 3.9.3 BASES (continued)

BACKGROUND These closure devices and lines connecting them to (continued) containment should be nonflammable and are not subject to Local Leak Rate Testing. Small bore tubing and flexible lines need not be seismically supported but should be protected from damage which could affect Containment Closure.

The routing of temporary services, such as breathing air through opened penetrations during fuel movement is permissible if the following conditions are established:

a. The area surrounding the service passing through the containment wall shall be sealed. This criteria may be met by using an existing pipe or cable penetration or by providing a method of sealing around the service pipe, hose or cable at the containment wall such that there can be no free passage of air between the containment atmosphere and the outside atmosphere.

b. If the service carries a liquid or gas, at least one end shall be closed such that there can be no free assage of air through the service'hose or pipe etween the containment atmosphere and the outside atmosphere. This requirement shall be able to be met even if pressure or flow is lost in the service system.

Check valves serving these lines prevent backflow from the containment atmosphere to the outside atmosphere.

Procedures for fulfilling proposed SURVEILLANCE REQUIREMENT 3.9.3.1 should contain provisions for identifying temporary services penetrating containment, and for determining that such penetrations satisfy the above criteria prior to fuel movement and periodically during fuel movement.

The requirements on containment penetration closure ensure that a release of fission product radioactivity within containment will be restricted from escaping to the environment.

The Containment Purge System includes two subsystems. The normal subsystem includes a 42 inch purge penetration and a 42 inch exhaust penetration. The second subsystem, a minipurge system, includes an 8 inch purge penetration and (continued)

SAN ONOFRE--UNIT 3 B 3.9-11 Amendment No. 116 10/10/97

Containment Penetrations B 3.9.3 BASES (continued)

BACKGROUND an 8 inch exhaust penetration. During MODES 1, 2, 3, and 4, (continued) the two valves in each of the normal purge and exhaust penetrations are secured in the closed position. The two valves in each of the two minipurge penetrations can be opened intermittently, but are closed automatically by the Containment Purge Isolation Signal (CPIS). Neither of the subsystems is subject to a Specification in MODE 5.

In MODE 6, large air exchanges are necessary to conduct refueling operations. The normal 42 inch purgesystem is used for this purpose and all valves are closed by the CPIS in accordance with LCO 3.3.8, "Containment Purge Isolation Signal (CPIS)."

The minipurge system is not normally used in MODE 6 with all four 8 inch valves in the closed position. However, as an alternative to normal purge, the minipurge system may be used in MODE 6 with CPIS operable.

The other containment penetrations that provide direct access from containment atmosphere to outside atmosphere must be isolated on at least one side. Isolation may be achieved by an OPERABLE automatic isolation valve, or by a manual isolation valve, blind flange, or equivalent.

Equivalent isolation methods must be approved and may include use of a material that can provide a temporary atmospheric pressure ventilation barrier for the other containment penetrations during fuel movements, APPLICABLE During CORE ALTERATIONS or movement of irrad*a-ted fuel SAFETY ANALYSIS assemblies within containment. the most severe radiological consequences result from a fuel handling accident. The fuel handling accident is a postulated event that involves damage to irradiated fuel (Ref. 1). Fuel handling accidents include dropping a single irr-ad *ei*fuel assembly and handling tool or a heavy object onto other irradiated fuel assemblies. The requirements of LCO 3.9.6, "Refueling Water Level," and the minimum decay time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months prior to CORE ALTERATIONS ensure that the release of fission product radioactivity, subsequent to a fuel handling accident, results in doses that are well within the guideline values specified in 10 CFR 100.

Containment penetrations satisfy Criterion 3 of the NRC Policy Statement.

(continued)

SAN ONOFRE--UNIT 3 B 3.9-12 Amendment No. 116 10/10/97

Containment Penetrations B 3.9.3 BASES (continued)

LCO This LCO limits the consequences of a fuel handling accident in containment by limiting the potential escape paths for fission product radioactivity released within containment.

The LCO requires any penetration providing direct access from the containment atmosphere to the outside atmosphere to be closed except for the OPERABLE containment purge and exhaust penetrations and the containment personnel airlock.

For the containment personnel airlock, this LCO ensures that the airlock can be closed after containment evacuation in the event of a fuel handling accident. The requirement that the plant be in Mode 6 with 23 feet of water above the fuel in the reactor vessel or defueled configuration with fuel in the containment (i.e., fuel in the refueling machine or upender) ensures that there is sufficient time to close the ersonnel airlock following a loss of shutdown cooling efore boiling occurs.

LCO part a. is modified by a NOTE:

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

The equipment hatch may be open if all of the following conditions are met:

1) The Containment Structure Equipment Hatch Shield Doors are capable of being closed within 30 minutes,

2) The plant is in Mode 6 with at least 23 feet of water above the reactor vessel flange,

3) A designated crew is available to close the Containment Structure Equipment Hatch Shield Doors, 43 Containment purge is in service, and The reactor has been subcritical for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

These restrictions include the administrative controls to allow the opening of the containment equipment hatch during CORE ALTERATIONS or movement of -rrad fuel in the containment provided that 1) The Containment Structure Equipment Hatch Shield Doors are capable of being closed within 30 minutes, 2) The plant is in Mode 6 with at least 23 feet of water above the reactor vessel flange, 3) A designated crew is available to close the Containment Structure Equipment Hatch Shield Doors, 4) Containment purge is in service, and 5) The reactor shall be subcritical for at least 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The Containment StructureEquipment Hatch Shield Doors include flashing on the top and sides of the shield doors which act to retard or restrict a release of post-accident fission products. The capability to close the containment shield doors includes requirements that the doors are capable of being closed and that any cables or hoses across the opening have quick disconnects to ensure the doors are capable of being closed within 30 minutes.

(continued)

SAN ONOFRE--UNIT 3 B 3.9-13 Amendment No.+-1--j-184 02/18y'05

.Containment Penetrations B 3.9.3 BASES (continued)

LCO The 30 minute closure time for the containment shield doors (continued) is considered to start when the control room communicates the need to shut the Containment Structure Equipment Hatch Shield Doors. This 30-minute requirement is significantly less than the fuel handl'ing accident analysis assumption that the containment remains open to the outside environment for a two-hour period subsequent to the accident. Placing containment purge (i.e., malIn purge exhaust with or without supply) in service will ensure any release from containment will be monitored.

The administrative controls will also specify the responsibility to be able to communicate with the control room, and specify the responsibility to ensure that the containment shield doors are capable of being closed in the event of a fuel handling accident. These administrative controls will ensure containment closure would be established in the event of a fuel handling accident inside containment .

LCO part b. is modified by a NOTE which allows both doors of the containment airlock to be open provided:

a. one personnel airlock door is OPERABLE, and b.1 the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel, or b.2 defueled configuration with fuel in containment (i.e., fuel in refueling machine or upender).

The OPERABILITY requirements ensure that the airlock door is capable of performing its function, and that a designated individual located outside of the affected area is available to close the door. For the OPERABLE containment p.urge and exhaust penetrations, this LCO ensures that these penetrations are isolable by the Containment Purge Isolation System. The OPERABILITY requirements for this LCO ensure that the automatic purge and exhaust valve closure times specified in the UFSAR can be achieved and therefore meet the assumptions used in the safety analysis to ensure releases through the valves are terminated, such that the radiological doses are within the acceptance limit.

APPLICABILITY The containment penetration requirements are applicable during CORE ALTERATIONS or movement of fuel

i-radiated ase li (11e.,1 1A iraiae f3::ýue

, n~ol-iraT laJelf , andj e-lin Ea-use this is when there is a potential for a fuel handling accident. In MODES 1, 2, 3, (continued)

SAN ONOFRE--UNIT 3 B 3.9-13a Amendment No.4-6--184 O2/,18/05 1

Containment Penetrations B 3.9.3 BASES (continued)

APPLICABILITY and 4, containment penetration requirements are addressed by (continued) LCO 3.6.1, "Containment." In MODES 5 and 6, when CORE ALTERATIONS or movement of irradiated fuel assemblies within containment are not being conducted, the potential for a fuel handling accident does not exist. Therefore, under these conditions no requirements are placed on containment penetration status ACTIONS A.1 and A.2 With the containment equipment hatch, air locks, or any containment penetration that provides direct access from the containment atmosphere to the outside atmosphere not in the required status, including the Containment Purge Isolation System not capable of automatic actuation when the purge and exhaust valves are open, the unit must be placed in a condition in which the isolation function is not needed.

This is accomplished by immediately suspending CORE ALTERATIONS and movement of irradiated fuel assemblies within containment. Performance of these actions shall not preclude completion of movement of a component to a safe position.

SURVEILLANCE SR 3.9.3.1 REQUIREMENTS This Surveillance demonstrates that each of the containment penetrations required to be in its closed position is in that position. The Surveillance on the open purge and exhaust Valves will demonstrate that the valves are not blocked from closing. Also, the Surveillance will demonstrate that each valve operator has motive power, which will ensure each valve is capable of being closed by an OPERABLE automatic Containment Purge Isolation Signal (CPIS).

The Surveillance is performed every 7 days during CORE ALTERATIONS or movement of irrad*--e*d fuel assemblies within the containment. As such, this Surveillance ensures that a postulated fuel handling accident that releases fission product radioactivity within the containment will not result in a release of fission product radioactivity to the environment.

(continued)

SAN ONOFRE--UNIT 3 B 3.9-14 Amendment No. 116 10/109n7-

Containment Penetrations B 3.9.3 BASES (continued)

SURVEILLANCE SR 3.9.3.2 REQUIREMENTS This Surveillance demonstrates that each containment purge and exha'ust valve actuates to its isolation position on an actual or simulated high radiation signal. The 24 month Frequency maintains consistency with other similar ESFAS instrumentation-and valve testing requi-rements. In LCO 3.3.8, "Containment Purge Isolation Signal," the Containment Purge Isolation Signal requires a CHANNEL CHECK every 7 days and a CHANNEL FUNCTIONAL TEST every 92 days to ensure the channel OPERABILITY during refueling operations.

Every 24 months a CHANNEL CALIBRATION is performed. The signal actuation response time is demonstrated every 24 months, during refueling, on a STAGGERED TEST BASIS.

SR 3.6.3.5 demonstrates that the isolation time of each valve is in accordance with the Inservice Testing Program requirements. These surveillances will ensure that the valves are capable of closing after postulated fuel handling accident to limit a release of fission product radioactivity from the containment.

REFERENCE 1. NUREG-0712, Safety Evaluation Report,related to the operation of San Onofre Nuclear Generating Station, Units 2 and 3, February 1981.

SAN ONOFRE--UNIT 3 B 3.9-15 Amendment No. 116 10/10/97

Refueling Water Level B 3.9.6 B 3.9 REFUELING OPERATIONS B 3.9.6 Refueling Water Level BASES BACKGROUND During movement of fuel assemblies or CEAs within the reactor pressure vessel when either the fu l ass.mb!i R ý being moved or the fuel assemblies seated within the reactr*

pressure vessel are irradiated, and during movement of jrrd,,ate4 fuel assemblies within containment, a minimum water level of 23 ft above the top of the reactor vessel flange is required. During refueling this maintains sufficient water level in the refueling canal and the fuel transfer canal. Sufficient water is necessary to retain iodine fission product activity in the water in the event of a fuel handling accident (Refs. I and 2). Sufficient iodine activity is well within the guidelines of IOCFR 100.

APPLICABLE SAFETY ANALYSES wit in the reactor pres urevesse assemblies being mved or the fuel aqembliFs saýt with',*im the reactor pressure vessel are irradiated, and during movement of irradiated fuel assemblies within containment, the water level in the refueling canal is an initial condition design parameter in the analysis of the fuel handling accident in containment postulated by Regulatory Guide 1.25 (Ref. 1). A minimum water level of 23 ft (Regulatory Position C.1.c of Ref. 1) allows a decontamination factor of 100 (Regulatory Position C.1.g of Ref. 1) to be used in the accident analysis for iodine.

This relates to the assumption that 99% of the total iodine released from the pellet to cladding gap of all the dropped fuel assembly rods is retained, by the refueling canal water.

The fuel pellet to cladding gap is assumed to contain 10% of the total fuel rod iodine inventory (Ref. 1).

The fuel handling accident analysis inside containment is described in Reference 2. With a minimum water level of 23 ft and a minimum decay time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months prior to fuel handling, the analysis and test programs demonstrate that.

the iodine release due to a postulated fuel handling accident is adequately captured by the water and offsite doses are maintained within allowable limits (Ref. 4).

Refueling water level satisfies Criterion 2 of the NRC Policy Statement.

(conti nued)

SAN ONOFRE--UNIT 3 B 3.9-25 Amendment No. 116 5/O3/97

Refueling Water Level B 3.9.6 BASES (continued)

APPLICABLE The applicability statement is modified by a note which SAFETY ANALYSES allows that the water level may be lowered to a minimum of (continued) 23 feet above the top of the fuel for movement of four finger CEAs, coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling.

LCO A minimum refueling water level of 23 ft above the reactor vessel flange is required to ensure that the radiological consequences of a postulated fuel handling accident inside containment are within acceptable limits as provided by the guidance of Reference 3..

APPLICABILITY LCO 3.9.6 is applicable during movement of fuel assemblies or CEAs within the reactor pressure vessel when either the I

fuel assemiblies being moved e fiel ass*erbli1s seated r thI wtth the reaetor pressure vessel are irradiated, and during movement of irradiat--ed fuel assemblies within containment.

A note provides an exception that the water level may be lowered to a minimum of 23 feet above the top of the fuel for movement of four finger CEAs, coupling and uncoupling of CEA extension shafts or for verifying the coupling and uncoupling. The LCO minimizes the possibility of a fuel handling accident in containment that is beyond the assumptions of the safety analysis. If irradiated fuel is not present in containment, therecan be no-significant radioactivity release as a result of a postulated fuel handling accident. Requirements for fuel handling accidents in the spent fuel pool are covered by LCO 3.7.16, "Fuel Storage Pool Water Level."

ACTIONS A.1 and A.2 With a water level of < 23 ft above the top of the reactor vessel flange, all operations involving CORE ALTERATIONS or movement of iradiated fuel assemblies in containment shall be suspended immediately to ensure that a fuel handling accident cannot occur.

The suspension of CORE ALTERATIONS and fuel movement shall not preclude completion of movement of a component to a safe position.

(continued)

SAN ONOFRE--UNIT 3 B 3.9-26 Amendment No. 116 0/43/198

Refueling Water Level B 3.9.6 BASES (continued)

SURVEILLANCE SR 3.9.6.1 REQUIREMENTS Verification of a minimum water level of 23 ft above the top of the reactor vessel flange ensures that the design basis for the postulated fuel handling accident analysis during refueling operations is met. Water at the required level above the top of the reactor vessel flange limits the consequences of damaged fuel rods that are postulated to result from a fuel handling accident inside containment (Ref. 2).

The.Frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is based on engineering judgment and is considered adequate in view of the large volume of water and the normal procedural controls of valve positions, which make significant unplanned level changes unlikely.

REFERENCES 1. Regulatory Guide 1.25, March 23, 1972.

2. UFSAR, Section 15.7..3.9.

3. NUREG-0712, Safety Evaluation Report related to the operation of San Onofre Nuclear Generating Station, Units 2 and 3, February 1981.

4. 10 CFR 100.10.

(continued)

SAN ONOFRE--UNIT 3 B 3.9-27 Amendment No. 116 10/13/98

v t e Letter Sequence Other
TAC:ME3136, (Withdrawn, Closed)
Initiation Acceptance Administration Questions 11 August 2010 Answers Results Withdrawal Other: ML100210200
MONTHYEAR2010-08-11 [Table View]

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