Text

Attachment 1, Volume 4, San Onofre Nuclear Generating Station - Improved Technical Specifications Conversion - ITS Section 3.1, Reactivity Control Systems
	ML11251A097
Person / Time
Site:	San Onofre
Issue date:	07/29/2011
From:	; Edison International Co, Southern California Edison Co
To:	; Office of Nuclear Reactor Regulation
References
	NUREG-1432, Rev. 3.0
	Download: ML11251A097 (345)
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Attachment 1, Volume 4, Rev. 0, Page 1 of 345 ATTACHMENT 1 VOLUME 4 SAN ONOFRE NUCLEAR GENERATING STATION IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.1 REACTIVITY CONTROL SYSTEMS Attachment 1, Volume 4, Rev. 0, Page 1 of 345

Attachment 1, Volume 4, Rev. 0, Page 2 of 345 LIST OF ATTACHMENTS

1. ITS 3.1.1 - SHUTDOWN MARGIN

2. ITS 3.1.3 - REACTIVITY BALANCE

3. ITS 3.1.4 - MODERATOR TEMPERATURE COEFFICIENT

4. ITS 3.1.5 - CEA ALIGNMENT

5. ITS 3.1.6 - SHUTDOWN CEA INSERTION LIMITS

6. ITS 3.1.7 - REGULATING CEA INSERTION LIIMITS

7. ITS 3.1.8 - PART LENGTH CEA INSERTION LIMITS

8. ITS 3.1.12 - STE - LOW POWER PHYSICS TESTING

9. ITS 3.1.13 - STE - AT POWER PHYSICS TESTING

10. ITS 3.1.14 - STE - REACTIVITY COEFFICIENT TESTING

11. ITS 3.1.15 - CEA POSITION INDICATION

12. RELOCATED/DELETED CTS

13. ISTS NOT ADOPTED IN SONGS ITS NOTE: There is no ITS 3.1.2, 3.1.9, 3.1.10, or 3.1.11.

Attachment 1, Volume 4, Rev. 0, Page 2 of 345

, Volume 4, Rev. 0, Page 3 of 345 ATTACHMENT 1 ITS 3.1.1, SHUTDOWN MARGIN (SDM) , Volume 4, Rev. 0, Page 3 of 345

Attachment 1, Volume 4, Rev. 0, Page 4 of 345 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 4, Rev. 0, Page 4 of 345

Attachment 1, Volume 4, Rev. 0, Page 5 of 345 ITS A01 A02 SDM T avg > 200EF 3.1.1 3.1 REACTIVITY CONTROL SYSTEMS 3.1.1 3.1.1 SHUTDOWN MARGIN (SDM) T > 200EF avg LCO 3.1.1 LCO 3.1.1 SDM shall be within the limits specified in the COLR.

Applicability APPLICABILITY: MODES 3 and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. SDM not within limit. A.1 Initiate boration to 15 minutes restore SDM to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 SR 3.1.1.1 Verify SDM is acceptable with increased 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after allowance for the withdrawn worth of detection of N ot U sed. inoperable CEAs. inoperable L01 CEA(s) and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter SR 3.1.1.2 SR 3.1.1.2 Verify SDM to be within the limits 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months specified in the COLR.

LA01 In accordance with the S urveillance Frequency C ontrol P rogram SAN ONOFRE--UNIT 2 3.1-1 Amendment No. 127,200 Attachment 1, Volume 4, Rev. 0, Page 5 of 345

Attachment 1, Volume 4, Rev. 0, Page 6 of 345 ITS A01 A02 SDM T avg # 200EF 3.1.2 3.1 REACTIVITY CONTROL SYSTEMS 3.1.1 3.1.2 SHUTDOWN MARGIN (SDM) T # 200EF avg LCO 3.1.1 LCO 3.1.2 SDM shall be within the limits specified in the COLR.

Applicability APPLICABILITY: MODE 5.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. SDM not within limit. A.1 Initiate boration to 15 minutes restore SDM to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.2 SR 3.1.2.1 Verify SDM to be within the limits 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months LA01 specified in the COLR.

In accordance with the S urveillance Frequency C ontrol P rogram SAN ONOFRE--UNIT 2 3.1-2 Amendment No. 127,200 Attachment 1, Volume 4, Rev. 0, Page 6 of 345

Attachment 1, Volume 4, Rev. 0, Page 7 of 345 ITS A01 A02 SDM T avg > 200EF 3.1.1 3.1 REACTIVITY CONTROL SYSTEMS 3.1.1 3.1.1 SHUTDOWN MARGIN (SDM) T > 200EF avg LCO 3.1.1 LCO 3.1.1 SDM shall be within the limits specified in the COLR.

Applicability APPLICABILITY: MODES 3 and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. SDM not within limit. A.1 Initiate boration to 15 minutes restore SDM to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 SR 3.1.1.1 Verify SDM is acceptable with increased 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after allowance for the withdrawn worth of detection of N ot U sed. inoperable CEAs. inoperable L01 CEA(s) and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter SR 3.1.1.2 SR 3.1.1.2 Verify SDM to be within the limits 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months specified in the COLR.

LA01 In accordance with the S urveillance Frequency C ontrol P rogram SAN ONOFRE--UNIT 3 3.1-1 Amendment No. 191 Attachment 1, Volume 4, Rev. 0, Page 7 of 345

Attachment 1, Volume 4, Rev. 0, Page 8 of 345 ITS A01 A02 SDM T avg # 200EF 3.1.2 3.1 REACTIVITY CONTROL SYSTEMS 3.1.1 3.1.2 SHUTDOWN MARGIN (SDM) T # 200EF avg LCO 3.1.1 LCO 3.1.2 SDM shall be within the limits specified in the COLR.

Applicability APPLICABILITY: MODE 5.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. SDM not within limit. A.1 Initiate boration to 15 minutes restore SDM to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.2 SR 3.1.2.1 Verify SDM to be within the limits 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months LA01 specified in the COLR.

In accordance with the S urveillance Frequency C ontrol P rogram SAN ONOFRE--UNIT 3 3.1-2 Amendment No. 191 Attachment 1, Volume 4, Rev. 0, Page 8 of 345

Attachment 1, Volume 4, Rev. 0, Page 9 of 345 DISCUSSION OF CHANGES ITS 3.1.1, SHUTDOWN MARGIN ADMINISTRATIVE CHANGES A01 In the conversion of the San Onofre Nuclear Generating Station (SONGS)

Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1432, Rev. 3.0, "Standard Technical Specifications Combustion Engineering Plants" (ISTS) and additional approved Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.1.1 provides the requirement for SHUTDOWN MARGIN (SDM) during MODES 3 and 4 and CTS 3.1.2 for SDM during MODE 5. ITS 3.1.1 provides the requirements for SDM during MODES 3, 4, and 5. This changes the CTS by combining the two Specifications (CTS 3.1.1 and CTS 3.1.2) into a single Specification (ITS 3.1.1).

CTS 3.1.1 and CTS 3.1.2 provide similar requirements, except for the Applicability and SR 3.1.1.1, which is being deleted by DOC L01. The wording of the LCO, ACTIONS, and Surveillance Requirements are the same. Combining these Specifications make the new combined ITS 3.1.1 applicable in MODES 3, 4, and 5 and eliminating the reference to temperature in the title will result in only a reorganization that removes redundancy that exist with two separate Specifications. This change will not affect the application of the SDM TS and as such is administrative.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 4 - Removal of LCO, SR, or other TS requirement to the LCS, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS SR 3.1.1.2 and CTS SR 3.1.2.1 require verification that SDM is within the limits specified in the COLR once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

ITS SR 3.1.1.2 requires a similar Surveillance, but specifies the periodic Frequency as "In accordance with the Surveillance Frequency Control Program."

This changes the CTS by moving the specified frequencies for the SRs and the Bases for the frequencies to the Surveillance Frequency Control Program.

San Onofre Unit 2 and 3 Page 1 of 5 Attachment 1, Volume 4, Rev. 0, Page 9 of 345

Attachment 1, Volume 4, Rev. 0, Page 10 of 345 DISCUSSION OF CHANGES ITS 3.1.1, SHUTDOWN MARGIN The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. In addition:

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program;

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1; and

c. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

The referenced document, NEI 04-10, Rev. 1, provides a detailed description of the process to be followed when considering changes to a Surveillance Frequency. NEI 04-10, Rev. 1, has been reviewed and approved by the NRC.

Therefore, the process will not be discussed further here.

The relocation of the specified Surveillance Frequencies to licensee control is consistent with Regulatory Guides 1.174 and 1.177. Regulatory Guide 1.177 provides guidance for changing Surveillance Frequencies and Completion Times.

However, for allowable risk changes associated with Surveillance Frequency extensions, it refers to Regulatory Guide 1.174, which provides quantitative risk acceptance guidelines for changes to core damage frequency (CDF) and large early release frequency (LERF). Regulatory Guide 1.174 provides additional guidelines that have been adapted in the risk-informed methodology for controlling changes to Surveillance Frequencies.

Regulatory Guide 1.174 identifies five key safety principles to be met for all risk-informed applications and to be explicitly addressed in risk-informed plant program change applications.

1. The proposed change meets the current regulations unless it is explicitly related to a requested exemption or rule change.

10 CFR 50.36(c) provides that TS will include items in the following categories:

(3) Surveillance requirements. Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

This change proposes to relocate various Frequencies for the performance of the Surveillance Requirements to a licensee-controlled program using an NRC approved methodology for control of the Surveillance Frequencies. The San Onofre Unit 2 and 3 Page 2 of 5 Attachment 1, Volume 4, Rev. 0, Page 10 of 345

Attachment 1, Volume 4, Rev. 0, Page 11 of 345 DISCUSSION OF CHANGES ITS 3.1.1, SHUTDOWN MARGIN Surveillance Requirements themselves will remain in TS. This is consistent with other NRC approved TS changes in which the Surveillance Frequencies are not under NRC control, such as Surveillances that are performed in accordance with the Inservice Testing Program or the Containment Leakage Rate Testing Program, where the Frequencies vary based on the past performance of the subject components. Thus, this proposed change meets criterion 1 above.

2. The proposed change is consistent with the defense-in-depth philosophy.

As described in Position 2.2.1.1 of Regulatory Guide 1.174, consistency with the defense-in-depth philosophy is maintained if:

A reasonable balance is preserved among prevention of core damage, prevention of containment failure, and consequence mitigation; Over-reliance on programmatic activities to compensate for weaknesses in plant design is avoided; System redundancy, independence, and diversity are preserved commensurate with the expected frequency, consequences of challenges to the system, and uncertainties (e.g., no risk outliers);

Defenses against potential common cause failures are preserved, and the potential for the introduction of new common cause failure mechanisms is assessed; Independence of barriers is not degraded; Defenses against human errors are preserved; and The intent of the General Design Criteria in 10 CFR Part 50, Appendix A is maintained.

These defense-in-depth objectives apply to all risk-informed applications, and for some of the issues involved (e.g., no over-reliance on programmatic activities and defense against human errors), it is fairly straightforward to apply them to this proposed change. The use of the multiple risk metrics of CDF and LERF and controlling the change resulting from the implementation of this initiative would maintain a balance between prevention of core damage, prevention of containment failure, and consequence mitigation.

Redundancy, diversity, and independence of safety systems are considered as part of the risk categorization to ensure that these qualities are not adversely affected. Independence of barriers and defense against common cause failures are also considered in the categorization. The improved understanding of the relative importance of plant components to risk resulting from the development of this program promotes an improved overall understanding of how the SSCs contribute to the plant's defense-in-depth.

San Onofre Unit 2 and 3 Page 3 of 5 Attachment 1, Volume 4, Rev. 0, Page 11 of 345

Attachment 1, Volume 4, Rev. 0, Page 12 of 345 DISCUSSION OF CHANGES ITS 3.1.1, SHUTDOWN MARGIN

3. The proposed change maintains sufficient safety margins.

Conformance with this principle is assured since SSC design, operation, testing methods and acceptance criteria specified in the Codes and Standards or alternatives approved for use by the NRC, will continue to be met as described in the plant licensing basis (e.g., UFSAR, or Technical Specifications Bases). Also, the safety analysis acceptance criteria in the licensing basis (e.g., UFSAR, supporting analyses, etc.) are met with the proposed change.

4. When proposed changes result in an increase in core damage frequency or risk, the increases should be small and consistent with the intent of the Commission's Safety Goal Policy Statement.

NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies,"

will require that changes in core damage frequency or risk are small and consistent with the intent of the Commission's Safety Goal Policy.

5. The impact of the proposed change should be monitored using performance measurement strategies.

NEI 04-10 will require that changes in Surveillance Frequencies be monitored using performance management strategies.

Therefore, the proposed change is consistent with the guidance in Regulatory Guide 1.174.

This change is designated as a less restrictive removal of detail change because the Surveillance Frequencies are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 7 - Relaxation of Surveillance Frequency) CTS SR 3.1.1.1 requires verification SDM is acceptable with increased allowance for the withdrawn worth of inoperable CEAs within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after detection of an inoperable CEA(s) and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. The ITS does not contain this SR but contains an SR (SR 3.1.1.2 which is similar to CTS SR 3.1.1.2) that requires verification of SDM every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This changes the CTS by decreasing the Surveillance Interval to verify SDM every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for all conditions including after detection of an inoperable CEA(s).

The purpose of CTS SR 3.1.1.1 is to verify SDM is acceptable with increased allowance for the withdrawn worth of inoperable CEAs within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months after detection of an inoperable CEA(s) and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. This change will delete this SR and rely on the existing SR (CTS SR 3.1.1.2) to verify SDM once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (the Frequency is being changed to be relocated to the Surveillance Frequency Control Program, DOC LA01). This change is acceptable because increasing the Frequency of SDM verification when one or more CEAs are inoperable is unnecessary. The current Frequency (ITS SR San Onofre Unit 2 and 3 Page 4 of 5 Attachment 1, Volume 4, Rev. 0, Page 12 of 345

Attachment 1, Volume 4, Rev. 0, Page 13 of 345 DISCUSSION OF CHANGES ITS 3.1.1, SHUTDOWN MARGIN 3.1.1.2) continues to ensure there is sufficient time to assess core conditions while considering the reduced available negative reactivity due to the inoperable CEAs. Additionally, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months frequency is based on the generally slow change in the required boron concentration, and the frequency also allows sufficient time for the operator to collect the required date, which includes performing a boron concentration analysis, and completion of the calculation.

This change does not affect the reactivity inputs into the calculation and it will continue to ensure the SDM is verified in sufficient time to take action is required.

Also, as part of this change the existing text for CTS SR 3.1.1.1 will be replaced with "Not used." This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

San Onofre Unit 2 and 3 Page 5 of 5 Attachment 1, Volume 4, Rev. 0, Page 13 of 345

Attachment 1, Volume 4, Rev. 0, Page 14 of 345 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 4, Rev. 0, Page 14 of 345

Attachment 1, Volume 4, Rev. 0, Page 15 of 345 SDM (Digital) 2 U2/U3 CTS 3.1.1 3.1 REACTIVITY CONTROL SYSTEMS 3.1.1 SHUTDOWN MARGIN (SDM) (Digital) 2 LCO 3.1.1, LCO 3.1.1 SDM shall be within the limits specified in the COLR.

LCO 3.1.2 3.1.1 and 3.1.2 APPLICABILITY: MODES 3, 4, and 5.

Applicability ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 3.1.1 and 3.1.2 A. SDM not within limit. A.1 Initiate boration to restore 15 minutes ACTION A SDM to within limit.

SURVEILLANCE REQUIREMENTS SR 3.1.1.1 Not used.

SURVEILLANCE FREQUENCY SR 3.1.1.2, SR 3.1.1.1 Verify SDM to be within the limits specified in the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 3 SR 3.1.2.1 TSTF-COLR. 425-A 2

In accordance with the Surveillance Frequency Control Program CEOG STS 3.1.1-1 Rev. 3.0, 03/31/04 1 San Onofre - Draft Amendment XXX Attachment 1, Volume 4, Rev. 0, Page 15 of 345

Attachment 1, Volume 4, Rev. 0, Page 16 of 345 JUSTIFICATION FOR DEVIATIONS ITS 3.1.1, SHUTDOWN MARGIN (SDM)

1. Changes are made (additions, deletions, and/or changes) to the ISTS which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The headings for ISTS 3.1.1 include the parenthetical expression "(Digital)." This identifying information is not included in the San Onofre Nuclear Generating Station (SONGS) ITS. This information is provided in the NUREG to assist in identifying the appropriate Specification to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific ITS implementation. SONGS Units 2 and 3 are digital plants; therefore analog requirements and specific labels that identify a requirement is digital are not required.

3. ISTS SR 3.1.1.1 is being renumbered to SR 3.1.1.2 and a new SR 3.1.1.1 is being added with the text, "Not used." The SONGS ITS SRs will retain, in most cases, the CTS numbering for SRs. This will prevent having to change plant procedures, which will put an unusual burden on the SONGS plant staff.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 4, Rev. 0, Page 16 of 345

Attachment 1, Volume 4, Rev. 0, Page 17 of 345 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 4, Rev. 0, Page 17 of 345

Attachment 1, Volume 4, Rev. 0, Page 18 of 345 SDM (Digital) 2 B 3.1.1 B 3.1 REACTIVITY CONTROL SYSTEMS B 3.1.1 SHUTDOWN MARGIN (SDM) (Digital) 2 BASES BACKGROUND The reactivity control systems must be redundant and capable of holding the reactor core subcritical when shutdown under cold conditions, in accordance with GDC 26 (Ref. 1). Maintenance of the SHUTDOWN MARGIN (SDM) ensures that postulated reactivity events will not damage the fuel. SDM requirements provide sufficient reactivity margin to ensure that acceptable fuel design limits will not be exceeded for normal shutdown and anticipated operational occurrences (AOOs). As such, the SDM defines the degree of subcriticality that would be obtained immediately following the insertion of all full length control element assemblies (CEAs), assuming the single CEA of highest reactivity worth is fully withdrawn.

The system design requires that two independent reactivity control systems be provided, and that one of these systems be capable of maintaining the core subcritical under cold conditions. These requirements are provided by the use of movable CEAs and soluble boric acid in the Reactor Coolant System (RCS). The CEA System provides the SDM during power operation and is capable of making the core subcritical rapidly enough to prevent exceeding acceptable fuel damage limits, assuming that the CEA of highest reactivity worth remains fully withdrawn.

The soluble boron system can compensate for fuel depletion during operation and all xenon burnout reactivity changes, and maintain the reactor subcritical under cold conditions.

During power operation, SDM control is ensured by operating with the 7

shutdown CEAs fully withdrawn and the regulating CEAs within the limits of LCO 3.1.6, "Regulating Control Element Assembly (CEA) Insertion 6 Limits." When the unit is in the shutdown and refueling modes, the SDM requirements are met by means of adjustments to the RCS boron concentration.

APPLICABLE The minimum required SDM is assumed as an initial condition in safety SAFETY analysis. The safety analysis (Ref. 2) establishes an SDM that ensures 4 ANALYSES specified acceptable fuel design limits are not exceeded for normal analyses operation and AOOs, with the assumption of the highest worth CEA stuck out following a reactor trip. For MODE 5, the primary safety analysis that relies on the SDM limits is the boron dilution analysis.

CEOG STS San Onofre - Draft B 3.1.1-1 Revision XXX Rev. 3.0, 03/31/04 1 Attachment 1, Volume 4, Rev. 0, Page 18 of 345

Attachment 1, Volume 4, Rev. 0, Page 19 of 345 SDM (Digital) A02 B 3.1.1 BASES APPLICABLE SAFETY ANALYSES (continued)

The acceptance criteria for the SDM are that specified acceptable fuel 4 design limits are maintained. This is done by ensuring that:

a. The reactor can be made subcritical from all operating conditions, transients, and Design Basis Events,

b. The reactivity transients associated with postulated accident conditions are controllable within acceptable limits (departure from nucleate boiling ratio (DNBR), fuel centerline temperature limit AOOs, and 280 cal/gm energy deposition for the CEA ejection accident),

and

c. The reactor will be maintained sufficiently subcritical to preclude inadvertent criticality in the shutdown condition.

in MODES 3, 4, and 5 is 1 4 occurring in MODE 1 or 2 The most limiting accident for the SDM requirements are based on a main 4 1

steam line break (MSLB), as described in the accident analysis (Ref. 2). analyses The increased steam flow resulting from a pipe break in the main steam 3 1 system causes an increased energy removal from the affected steam generator (SG), and consequently the RCS. This results in a reduction of the reactor coolant temperature. The resultant coolant shrinkage causes a reduction in pressure. In the presence of a negative moderator temperature coefficient, this cooldown causes an increase in core reactivity. As RCS temperature decreases, the severity of an MSLB 1 decreases until the MODE 5 value is reached. The most limiting MSLB, with respect to potential fuel damage before a reactor trip occurs, is a guillotine break of a main steam line inside containment initiated at the end of core life. The positive reactivity addition from the moderator temperature decrease will terminate when the affected SG boils dry, thus terminating RCS heat removal and cooldown. Following the MSLB, a post trip return to power may occur; however, no fuel damage occurs as a result of the post trip return to power, and THERMAL POWER does not violate the Safety Limit (SL) requirement of SL 2.1.1.

In addition to the limiting MSLB transient, the SDM requirement for MODES 3 and 4 must also protect against:

a. Inadvertent boron dilution,

b. An uncontrolled CEA withdrawal from a subcritical condition,

c. Startup of an inactive reactor coolant pump (RCP), and

d. CEA ejection.

CEOG STS San Onofre - Draft B 3.1.1-2 Revision XXX Rev. 3.0, 03/31/04 1 Attachment 1, Volume 4, Rev. 0, Page 19 of 345

Attachment 1, Volume 4, Rev. 0, Page 20 of 345 SDM (Digital) 2 B 3.1.1 BASES APPLICABLE SAFETY ANALYSES (continued)

Each of these is discussed below.

In the boron dilution analysis, the required SDM defines the reactivity difference between an initial subcritical boron concentration and the corresponding critical boron concentration. These values, in conjunction with the configuration of the RCS and the assumed dilution flow rate, directly affect the results of the analysis. This event is most limiting at the beginning of core life when critical boron concentrations are highest.

The withdrawal of CEAs from subcritical conditions adds reactivity to the reactor core, causing both the core power level and heat flux to increase 8

with corresponding increases in reactor coolant temperatures and pressure. The withdrawal of CEAs also produces a time dependent redistribution of core power.

Depending on the system initial conditions and reactivity insertion rate, the uncontrolled CEA withdrawal transient is terminated by either a high power level trip or a high pressurizer pressure trip. In all cases, power level, RCS pressure, linear heat rate, and the DNBR do not exceed allowable limits.

The startup of an inactive RCP will not result in a "cold water" criticality, 1 even if the maximum difference in temperature exists between the SG and the core. The maximum positive reactivity addition that can occur due to an inadvertent RCP start is less than half the minimum required 1 SDM. An idle RCP cannot, therefore, produce a return to power from the hot standby condition.

The withdrawal of CEAs from subcritical or low power Conditions adds reactivity to the reactor core, causing both the core power level and heat flux to increase with corresponding increases in reactor coolant temperatures and pressure. The withdrawal of CEAs also produces a time dependent redistribution of core power.

The SDM satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

3 4 LCO The MSLB (Ref. 2) and the boron dilution (Ref. 3) accidents are the most 1 limiting analyses that establish the SDM value of the LCO. For MSLB 10 CFR 50.67, "Accident Source accidents, if the LCO is violated, there is a potential to exceed the DNBR 1 5

Term limit and to exceed 10 CFR 100, "Reactor Site Criterion," limits (Ref. 4).

For the boron dilution accident, if the LCO is violated, then the minimum required time assumed for operator action to terminate dilution may no longer be applicable.

CEOG STS San Onofre - Draft B 3.1.1-3 Revision XXX Rev. 3.0, 03/31/04 1 Attachment 1, Volume 4, Rev. 0, Page 20 of 345

Attachment 1, Volume 4, Rev. 0, Page 21 of 345 SDM (Digital) 2 B 3.1.1 BASES LCO (continued)

SDM is a core physics design condition that can be ensured through CEA positioning (regulating and shutdown CEAs) and through the soluble boron concentration.

APPLICABILITY In MODES 3, 4, and 5, the SDM requirements are applicable to provide sufficient negative reactivity to meet the assumptions of the safety 6

analyses discussed above. In MODES 1 and 2, SDM is ensured by complying with LCO 3.1.5, "Shutdown Control Element Assembly (CEA) 7 6 Insertion Limits," and LCO 3.1.6. In MODE 6, the shutdown reactivity requirements are given in LCO 3.9.1, "Boron Concentration."

ACTIONS A.1 If the SDM requirements are not met, boration must be initiated promptly.

A Completion Time of 15 minutes is adequate for an operator to correctly align and start the required systems and components. It is assumed that boration will be continued until the SDM requirements are met.

In the determination of the required combination of boration flow rate and boron concentration, there is no unique requirement that must be satisfied. Since it is imperative to raise the boron concentration of the RCS as soon as possible, the boron concentration should be a highly makeup tanks concentrated solution, such as that normally found in the boric acid 1

storage tank or the borated water storage tank. The operator should borate with the best source available for the plant conditions.

refueling in 4 In determining the boration flow rate, the time core life must be maximum required considered. For instance, the most difficult time in core life to increase is high. the RCS boron concentration is at the beginning of cycle, when the boron concentration may approach or exceed 2000 ppm. Assuming that a value of 1% k/k must be recovered and a boration flow rate of [ ] gpm, it is possible to increase the boron concentration of the RCS by 100 ppm in approximately 35 minutes. If a boron worth of 10 pcm/ppm is assumed, 9 this combination of parameters will increase the SDM by 1% k/k. These boration parameters of [ ] gpm and [ ] ppm represent typical values and are provided for the purpose of offering a specific example.

CEOG STS San Onofre - Draft B 3.1.1-4 Revision XXX Rev. 3.0, 03/31/04 1 Attachment 1, Volume 4, Rev. 0, Page 21 of 345

Attachment 1, Volume 4, Rev. 0, Page 22 of 345 SDM (Digital) 2 B 3.1.1 SR 3.1.1.1 Not Used.

BASES 2 6 SURVEILLANCE SR 3.1.1.1 REQUIREMENTS SDM is verified by performing a reactivity balance calculation, considering the listed reactivity effects:

a. RCS boron concentration,

b. CEA positions,

c. RCS average temperature,

d. Fuel burnup based on gross thermal energy generation,

e. Xenon concentration,

f. Samarium concentration, and

g. Isothermal temperature coefficient (ITC).

Using the ITC accounts for Doppler reactivity in this calculation because the reactor is subcritical, and the fuel temperature will be changing at the same rate as the RCS.

The Frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is based on the generally slow change in TSTF-INSERT 1 required boron concentration, and also allows sufficient time for the 425-A operator to collect the required data, which includes performing a boron concentration analysis, and complete the calculation.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 26.

3 2. UFSAR, Chapter 15.

2. FSAR, Section [15.4.2].

U 1.3.1 3 4.1.4 4 1

3. FSAR, Section [15.4.2].

5 50.67

4. 10 CFR 100.

CEOG STS B 3.1.1-5 Rev. 3.0, 03/31/04 1 San Onofre - Draft Revision XXX Attachment 1, Volume 4, Rev. 0, Page 22 of 345

Attachment 1, Volume 4, Rev. 0, Page 23 of 345 B 3.1.1 TSTF-425-A INSERT 1 The Frequency is controlled under the Surveillance Frequency Control Program. 7

Reviewer's Note-------------------------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program 5

should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

Insert Page B 3.1-5 Attachment 1, Volume 4, Rev. 0, Page 23 of 345

Attachment 1, Volume 4, Rev. 0, Page 24 of 345 JUSTIFICATION FOR DEVIATIONS ITS 3.1.1 BASES, SHUTDOWN MARGIN (SDM)

1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The headings for ISTS 3.1.1 Bases include the parenthetical expression "(Digital)."

This identifying information is not included in the San Onofre Nuclear Generating Station (SONGS) ITS. This information is provided in the NUREG to assist in identifying the appropriate Specification to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific ITS implementation.

SONGS Units 2 and 3 are digital plants; therefore analog requirements and specific labels that identify a requirement is digital are not required.

3. The ISTS contains bracketed information and/or values that are generic to all Combustion Engineering vintage plants. The brackets are removed and the proper plant specific information/value is provided. This is acceptable since the information/value is revised to reflect the current licensing basis.

4. These changes are grammatical corrections, correcting punctuation, or other changes that are consistent with the Writers Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01.

5. This "Reviewers Note" is being deleted. The Reviewers Note is for the NRC reviewer during the NRC review and will not be part of the plant specific SONGS ITS.

6. Changes are made to be consistent with changes made to the Specification.

7. The Bases words changed by TSTF-425 have been modified to state "The Frequency is controlled under the Surveillance Frequency Control Program." The Surveillance Frequency Control Program provides the details for how to change the Frequencies, thus the TSTF-425 words concerning operating experience, equipment reliability, and plant risk is not always true for each of the Frequencies.

8. ISTS 3.1.1 Applicable Safety Analyses (ASA) Section contains two paragraphs that are redundant except for the words, "or low power," in one of the paragraphs. The paragraph without, "or low power," is being deleted. This change has no affect on the ASA section.

9. The last paragraph in the ISTS 3.1.1 Bases Section for ACTION A.1 is being revised to reflect that that boration requirements change over the life of the core, with the most limiting time being at beginning of life, which is the intent of this Bases paragraph. The specific information in the ISTS is cycle specific at San Onofre and may require changes each fuel cycle which is not the intent of the ITS Bases; therefore, the paragraph is being revised to provide the information desired while eliminating the cycle specific information.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 4, Rev. 0, Page 24 of 345

Attachment 1, Volume 4, Rev. 0, Page 25 of 345 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 4, Rev. 0, Page 25 of 345

Attachment 1, Volume 4, Rev. 0, Page 26 of 345 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.1.1, SHUTDOWN MARGIN (SDM)

There were no specific No Significant Hazards Considerations for this Specification.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 4, Rev. 0, Page 26 of 345

, Volume 4, Rev. 0, Page 27 of 345 ATTACHMENT 2 ITS 3.1.3, REACTIVITY BALANCE , Volume 4, Rev. 0, Page 27 of 345

, Volume 4, Rev. 0, Page 28 of 345 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 4, Rev. 0, Page 28 of 345

Attachment 1, Volume 4, Rev. 0, Page 29 of 345 ITS A01 Reactivity Balance 3.1.3 3.1 REACTIVITY CONTROL SYSTEMS 3.1.3 3.1.3 Reactivity Balance LCO 3.1.3 LCO 3.1.3 The core reactivity balance shall be within +/- 1% k/k of predicted values.

Applicability APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. Core reactivity A.1 Re-evaluate core 7 days balance not within design and safety limit. analysis and determine that the reactor core is acceptable for continued operation.

AND A.2 Establish appropriate 7 days operating restrictions and SRs.

ACTION B 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.

SAN ONOFRE--UNIT 2 3.1-3 Amendment No. 127,200 Attachment 1, Volume 4, Rev. 0, Page 29 of 345

Attachment 1, Volume 4, Rev. 0, Page 30 of 345 ITS Reactivity Balance A01 3.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 SR 3.1.3.1 -------------------NOTES-------------------

1. The predicted reactivity values may be adjusted (normalized) to correspond to the measured core reactivity prior to exceeding a fuel burnup of 60 effective full power days (EFPD) after each fuel loading. Prior to entering MODE 1 after

2. This Surveillance is not required to fuel loading be performed prior to entering AND MODES 1 or 2. M01 Verify overall core reactivity balance is ----NOTE-----

within +/- 1.0% k/k of predicted values. Only required LA01 after 60 EFPD 31 EFPD LA01 In accordance with the Surveillance Frequency Control Program SAN ONOFRE--UNIT 2 3.1-4 Amendment No. 127 Attachment 1, Volume 4, Rev. 0, Page 30 of 345

Attachment 1, Volume 4, Rev. 0, Page 31 of 345 ITS A01 Reactivity Balance 3.1.3 3.1 REACTIVITY CONTROL SYSTEMS 3.1.3 3.1.3 Reactivity Balance LCO 3.1.3 LCO 3.1.3 The core reactivity balance shall be within +/- 1% k/k of predicted values.

Applicability APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. Core reactivity A.1 Re-evaluate core 7 days balance not within design and safety limit. analysis and determine that the reactor core is acceptable for continued operation.

AND A.2 Establish appropriate 7 days operating restrictions and SRs.

ACTION B 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.

SAN ONOFRE--UNIT 3 3.1-3 Amendment No. 116,191 Attachment 1, Volume 4, Rev. 0, Page 31 of 345

Attachment 1, Volume 4, Rev. 0, Page 32 of 345 ITS Reactivity Balance A01 3.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 SR 3.1.3.1 -------------------NOTES-------------------

1. The predicted reactivity values may be adjusted (normalized) to correspond to the measured core reactivity prior to exceeding a fuel burnup of 60 effective full power days (EFPD) after each fuel loading. Prior to entering MODE 1 after

2. This Surveillance is not required to fuel loading be performed prior to entering AND MODES 1 or 2. M01 Verify overall core reactivity balance is ----NOTE-----

within +/- 1.0% k/k of predicted values. Only required LA01 after 60 EFPD 31 EFPD LA01 In accordance with the Surveillance Frequency Control Program SAN ONOFRE--UNIT 3 3.1-4 Amendment No. 116 Attachment 1, Volume 4, Rev. 0, Page 32 of 345

Attachment 1, Volume 4, Rev. 0, Page 33 of 345 DISCUSSION OF CHANGES ITS 3.1.3, REACTIVITY BALANCE ADMINISTRATIVE CHANGES A01 In the conversion of the San Onofre Nuclear Generating Station (SONGS)

Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1432, Rev. 3.0, "Standard Technical Specifications Combustion Engineering Plants" (ISTS) and additional approved Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS SR 3.1.3.1 requires the verification of overall core reactivity balance every 31 EFPD. The SR is modified by a Note in the Surveillance column that allows entry into MODES 1 and 2 without performing the Surveillance. It is also modified by a Note in the Frequency column which allows the SR to only be performed after 60 EFPD. Thus the CTS allows entry and operation in MODE 1 for up to 60 EFPD prior to requiring a reactivity balance verification. ITS SR 3.1.3.1, in part, requires the Surveillance to be performed prior to entering MODE 1 after fuel loading. The ITS contains a Note in the Surveillance column that only allows entry into MODE 2 without performing the SR. This changes the CTS by requiring the first performance of the SR to be prior to entering MODE 1 after fuel loading.

The purpose of CTS SR 3.1.3.1 is to ensure the reactivity balance is within predicted values. This change will ensure the limits on core reactivity are within the required limit before entering MODE 1 anytime fuel has been loaded into the core. It ensures the SR is performed prior to entering MODE 1 as an initial check on core conditions and design calculations at beginning of cycle (BOC). A reactivity balance must exist when the reactor is critical or producing THERMAL POWER. As the fuel depletes, core conditions are changing, and confirmation of the reactivity balance ensures the core is operating as designed. Therefore, this change is acceptable. Requiring the SR to be performed prior to entering MODE 1 versus allowing the performance of the SR following entry into MODE 1 after 60 EFPD is more restrictive.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 4 - Removal of LCO, SR, or other TS requirement to the LCS, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS SR 3.1.3.1 requires verification that the overall core reactivity balance is within +/- 1.0% k/k of predicted values once per San Onofre Unit 2 and 3 Page 1 of 4 Attachment 1, Volume 4, Rev. 0, Page 33 of 345

Attachment 1, Volume 4, Rev. 0, Page 34 of 345 DISCUSSION OF CHANGES ITS 3.1.3, REACTIVITY BALANCE 31 days. The Surveillance Frequency is modified by a Note which only requires the SR after 60 EFPD. ITS SR 3.1.3.1 requires a similar Surveillance, but specifies the periodic Frequency as "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified frequency and the accompanying Note for the SR and the Bases for the frequency to the Surveillance Frequency Control Program.

The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. In addition:

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program;

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1; and

c. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

The referenced document, NEI 04-10, Rev. 1, provides a detailed description of the process to be followed when considering changes to a Surveillance Frequency. NEI 04-10, Rev. 1, has been reviewed and approved by the NRC.

Therefore, the process will not be discussed further here.

The relocation of the specified Surveillance Frequencies to licensee control is consistent with Regulatory Guides 1.174 and 1.177. Regulatory Guide 1.177 provides guidance for changing Surveillance Frequencies and Completion Times.

However, for allowable risk changes associated with Surveillance Frequency extensions, it refers to Regulatory Guide 1.174, which provides quantitative risk acceptance guidelines for changes to core damage frequency (CDF) and large early release frequency (LERF). Regulatory Guide 1.174 provides additional guidelines that have been adapted in the risk-informed methodology for controlling changes to Surveillance Frequencies.

Regulatory Guide 1.174 identifies five key safety principles to be met for all risk-informed applications and to be explicitly addressed in risk-informed plant program change applications.

1. The proposed change meets the current regulations unless it is explicitly related to a requested exemption or rule change.

10 CFR 50.36(c) provides that TS will include items in the following categories:

San Onofre Unit 2 and 3 Page 2 of 4 Attachment 1, Volume 4, Rev. 0, Page 34 of 345

Attachment 1, Volume 4, Rev. 0, Page 35 of 345 DISCUSSION OF CHANGES ITS 3.1.3, REACTIVITY BALANCE (3) Surveillance requirements. Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

This change proposes to relocate various Frequencies for the performance of the Surveillance Requirements to a licensee-controlled program using an NRC approved methodology for control of the Surveillance Frequencies. The Surveillance Requirements themselves will remain in TS. This is consistent with other NRC approved TS changes in which the Surveillance Frequencies are not under NRC control, such as Surveillances that are performed in accordance with the Inservice Testing Program or the Containment Leakage Rate Testing Program, where the Frequencies vary based on the past performance of the subject components. Thus, this proposed change meets criterion 1 above.

2. The proposed change is consistent with the defense-in-depth philosophy.

As described in Position 2.2.1.1 of Regulatory Guide 1.174, consistency with the defense-in-depth philosophy is maintained if:

A reasonable balance is preserved among prevention of core damage, prevention of containment failure, and consequence mitigation; Over-reliance on programmatic activities to compensate for weaknesses in plant design is avoided; System redundancy, independence, and diversity are preserved commensurate with the expected frequency, consequences of challenges to the system, and uncertainties (e.g., no risk outliers);

Defenses against potential common cause failures are preserved, and the potential for the introduction of new common cause failure mechanisms is assessed; Independence of barriers is not degraded; Defenses against human errors are preserved; and The intent of the General Design Criteria in 10 CFR Part 50, Appendix A is maintained.

These defense-in-depth objectives apply to all risk-informed applications, and for some of the issues involved (e.g., no over-reliance on programmatic activities and defense against human errors), it is fairly straightforward to apply them to this proposed change. The use of the multiple risk metrics of CDF and LERF and controlling the change resulting from the implementation of this initiative would maintain a balance between prevention of core San Onofre Unit 2 and 3 Page 3 of 4 Attachment 1, Volume 4, Rev. 0, Page 35 of 345

Attachment 1, Volume 4, Rev. 0, Page 36 of 345 DISCUSSION OF CHANGES ITS 3.1.3, REACTIVITY BALANCE damage, prevention of containment failure, and consequence mitigation.

Redundancy, diversity, and independence of safety systems are considered as part of the risk categorization to ensure that these qualities are not adversely affected. Independence of barriers and defense against common cause failures are also considered in the categorization. The improved understanding of the relative importance of plant components to risk resulting from the development of this program promotes an improved overall understanding of how the SSCs contribute to the plant's defense-in-depth.

3. The proposed change maintains sufficient safety margins.

Conformance with this principle is assured since SSC design, operation, testing methods and acceptance criteria specified in the Codes and Standards or alternatives approved for use by the NRC, will continue to be met as described in the plant licensing basis (e.g., UFSAR, or Technical Specifications Bases). Also, the safety analysis acceptance criteria in the licensing basis (e.g., UFSAR, supporting analyses, etc.) are met with the proposed change.

4. When proposed changes result in an increase in core damage frequency or risk, the increases should be small and consistent with the intent of the Commission's Safety Goal Policy Statement.

NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies,"

will require that changes in core damage frequency or risk are small and consistent with the intent of the Commission's Safety Goal Policy.

5. The impact of the proposed change should be monitored using performance measurement strategies.

NEI 04-10 will require that changes in Surveillance Frequencies be monitored using performance management strategies.

Therefore, the proposed change is consistent with the guidance in Regulatory Guide 1.174.

This change is designated as a less restrictive removal of detail change because a Surveillance Frequency is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES None San Onofre Unit 2 and 3 Page 4 of 4 Attachment 1, Volume 4, Rev. 0, Page 36 of 345

Attachment 1, Volume 4, Rev. 0, Page 37 of 345 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 4, Rev. 0, Page 37 of 345

Attachment 1, Volume 4, Rev. 0, Page 38 of 345 2

Reactivity Balance (Digital)

U2/U3 CTS 3.1.2 4 3

3.1 REACTIVITY CONTROL SYSTEMS 4 2 3.1.2 Reactivity Balance (Digital) 3 LCO 3.1.3 LCO 3.1.2 The core reactivity balance shall be within +/- 1% k/k of predicted values. 4 3

Applicability APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. Core reactivity balance A.1 Re-evaluate core design 7 days not within limit. and safety analysis and determine that the reactor core is acceptable for continued operation.

AND A.2 Establish appropriate 7 days operating restrictions and SRs.

ACTION B 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.

CEOG STS 3.1.2-1 Rev. 3.0, 03/31/04 1 4 San Onofre - Draft 3 Amendment XXX Attachment 1, Volume 4, Rev. 0, Page 38 of 345

Attachment 1, Volume 4, Rev. 0, Page 39 of 345 2

Reactivity Balance (Digital)

U2/U3 CTS 3.1.2 4 3

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 SR 3.1.2.1 ------------------------------NOTES----------------------------- 4 3 1. The predicted reactivity values may be adjusted (normalized) to correspond to the measured core reactivity prior to exceeding a fuel burnup of 60 effective full power days (EFPD) after each fuel loading.

2. This Surveillance is not required to be performed prior to entry into MODE 2.

Verify overall core reactivity balance is within Prior to entering

+/- 1.0% k/k of predicted values. MODE 1 after fuel loading AND

NOTE--------

Only required 3 after 60 EFPD TSTF-31 EFPD 425-A In accordance with the Surveillance Frequency Control Program CEOG STS 3.1.2-2 Rev. 3.0, 03/31/04 1 4 San Onofre - Draft 3 Amendment XXX Attachment 1, Volume 4, Rev. 0, Page 39 of 345

Attachment 1, Volume 4, Rev. 0, Page 40 of 345 JUSTIFICATION FOR DEVIATIONS ITS 3.1.3, REACTIVITY BALANCE

1. Changes are made (additions, deletions, and/or changes) to the ISTS which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The headings for ISTS 3.1.2 (ITS 3.1.3) include the parenthetical expression

"(Digital)." This identifying information is not included in the San Onofre Nuclear Generating Station (SONGS) ITS. This information is provided in the NUREG to assist in identifying the appropriate Specification to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific ITS implementation. SONGS Units 2 and 3 are digital plants; therefore analog requirements and specific labels that identify a requirement is digital are not required.

3. This change to ISTS SR 3.1.2.1 (ITS SR 3.1.3.1) deletes the Note that modifies the second Frequency for the verification of core reactivity. This change, while not currently included in TSTF-425, is required in conjunction with the adoption of this TSTF. This TSTF relocates Surveillance Frequencies to the Surveillance Frequency Control Program. Any limitations or allowances that modify the current 31 EFPD Frequency (such as "only required after 60 EFPD") will be specified along with the Frequency in this program.

4. The Specification/SR number has been changed to be consistent with the Specification number in the SONGS CTS. SONGS CTS contained two SDM Specifications (CTS 3.1.1, SDM in MODES 3 and 4, and CTS 3.1.2, SDM in MODE 5) which are being combined into one Specification (ITS 3.1.1), consistent with NUREG-1432. SCE has decided not to renumber the CTS to be consistent with the ISTS because by doing so would result in the unnecessary administrative burden of changing TS numbers in plant procedures.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 4, Rev. 0, Page 40 of 345

Attachment 1, Volume 4, Rev. 0, Page 41 of 345 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 4, Rev. 0, Page 41 of 345

Attachment 1, Volume 4, Rev. 0, Page 42 of 345 2

Reactivity Balance (Digital)

B 3.1.2 6 3

B 3.1 REACTIVITY CONTROL SYSTEMS B 3.1.2 Reactivity Balance (Digital) 6 2 3

BASES BACKGROUND According to GDC 26, GDC 28, and GDC 29 (Ref. 1), reactivity shall be controllable, such that, subcriticality is maintained under cold conditions, and acceptable fuel design limits are not exceeded during normal operation and anticipated operational occurrences. Therefore, reactivity balance is used as a measure of the predicted versus measured core reactivity during power operation. The periodic confirmation of core reactivity is necessary to ensure that Design Basis Accident (DBA) and transient safety analyses remain valid. A large reactivity difference could be the result of unanticipated changes in fuel, control element assembly 4

(CEA) worth, or operation at Conditions not consistent with those assumed in the predictions of core reactivity, and could potentially result in a loss of SDM or violation of acceptable fuel design limits. Comparing predicted versus measured core reactivity validates the nuclear methods used in the safety analysis and supports the SDM demonstrations (LCO 3.1.1, "SHUTDOWN MARGIN (SDM)") in ensuring the reactor can be brought safely to cold, subcritical conditions.

When the reactor core is critical or in normal power operation, a reactivity balance exists and the net reactivity is zero. A comparison of predicted and measured reactivity is convenient under such a balance, since parameters are being maintained relatively stable under steady state power conditions. The positive reactivity inherent in the core design is balanced by the negative reactivity of the control components, thermal feedback, neutron leakage, and materials in the core that absorb neutrons, such as burnable absorbers producing zero net reactivity.

Excess reactivity can be inferred from the critical boron curve, which provides an indication of the soluble boron concentration in the Reactor Coolant System (RCS) versus cycle burnup. Periodic measurement of the RCS boron concentration for comparison with the predicted value with other variables fixed (such as CEA height, temperature, pressure, and power) provides a convenient method of ensuring that core reactivity is within design expectations, and that the calculational models used to generate the safety analysis are adequate.

In order to achieve the required fuel cycle energy output, the uranium enrichment in the new fuel loading and in the fuel remaining from the previous cycle, provides excess positive reactivity beyond that required to sustain steady state operation throughout the cycle. When the reactor is rated 11 critical at RTP and moderator temperature, the excess positive reactivity 4 is compensated by burnable absorbers (if any), CEAs, whatever neutron poisons (mainly xenon and samarium) are present in the fuel, and the RCS boron concentration.

CEOG STS B 3.1.2-1 Rev. 3.0, 03/31/04 1 6 San Onofre - Draft 3 Revision XXX Attachment 1, Volume 4, Rev. 0, Page 42 of 345

Attachment 1, Volume 4, Rev. 0, Page 43 of 345 2

Reactivity Balance (Digital)

B 3.1.2 6 3

BASES BACKGROUND (continued)

When the core is producing THERMAL POWER, the fuel is being depleted and excess reactivity is decreasing. As the fuel depletes, the RCS boron concentration is reduced to decrease negative reactivity and maintain constant THERMAL POWER. The critical boron curve is based on steady state operation at RTP. Therefore, deviations from the predicted boron letdown curve may indicate deficiencies in the design analysis, deficiencies in the calculational models, or abnormal core conditions, and must be evaluated.

APPLICABLE Accurate prediction of core reactivity is either an explicit or implicit SAFETY assumption in the accident analysis evaluations. Every accident ANALYSES evaluation (Ref. 2) is, therefore, dependent upon accurate evaluation of core reactivity. In particular, SDM, and reactivity transients such as CEA withdrawal accidents or CEA ejection accidents, are very sensitive to accurate prediction of core reactivity. These accident analysis evaluations rely on computer codes that have been qualified against available test data, operating plant data, and analytical benchmarks.

Monitoring reactivity balance additionally ensures that the nuclear methods provide an accurate representation of the core reactivity.

Design calculations and safety analyses are performed for each fuel cycle for the purpose of predetermining reactivity behavior and the RCS boron concentration requirements for reactivity control during fuel depletion.

The comparison between measured and predicted initial core reactivity provides a normalization for calculational models used to predict core reactivity. If the measured and predicted RCS boron concentrations for identical core conditions at beginning of cycle (BOC) do not agree, then the assumptions used in the reload cycle design analysis or the calculational models used to predict soluble boron requirements may not be accurate. If reasonable agreement between measured and predicted core reactivity exists at BOC, then the prediction may be normalized to the measured boron concentration. Thereafter, any significant deviations in the measured boron concentration from the predicted critical boron curve that develop during fuel depletion may be an indication that the calculational model is not adequate for core burnups beyond BOC, or that an unexpected change in core conditions has occurred.

CEOG STS B 3.1.2-2 Rev. 3.0, 03/31/04 1 6 San Onofre - Draft 3 Revision XXX Attachment 1, Volume 4, Rev. 0, Page 43 of 345

Attachment 1, Volume 4, Rev. 0, Page 44 of 345 2

Reactivity Balance (Digital)

B 3.1.2 6

3 BASES APPLICABLE SAFETY ANALYSES (continued)

The normalization of predicted RCS boron concentration to the measured value is typically performed after reaching RTP following startup from a refueling outage, with the CEAs in their normal positions for power operation. The normalization is performed at BOC conditions, so that core reactivity relative to predicted values can be continually monitored and evaluated as core conditions change during the cycle.

The reactivity balance satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The reactivity balance limit is established to ensure plant operation is maintained within the assumptions of the safety analyses. Large differences between actual and predicted core reactivity may indicate that the assumptions of the DBA and transient analyses are no longer valid, or that the uncertainties in the nuclear design methodology are larger than expected. A limit on the reactivity balance of +/- 1% k/k has been established, based on engineering judgment. A 1% deviation in reactivity from that predicted is larger than expected for normal operation, and should therefore be evaluated.

When measured core reactivity is within 1% k/k of the predicted value at steady state thermal conditions, the core is considered to be operating within acceptable design limits. Since deviations from the limit are normally detected by comparing predicted and measured steady state RCS critical boron concentrations, the difference between measured and predicted values would be approximately 100 ppm (depending on the boron worth) before the limit is reached. These values are well within the uncertainty limits for analysis of boron concentration samples, so that spurious violations of the limit due to uncertainty in measuring the RCS boron concentration are unlikely.

APPLICABILITY The limits on core reactivity must be maintained during MODES 1 and 2 because a reactivity balance must exist when the reactor is critical or producing THERMAL POWER. As the fuel depletes, core conditions are changing, and confirmation of the reactivity balance ensures the core is operating as designed. This Specification does not apply in MODES 3, 4, and 5 because the reactor is shut down and the reactivity balance is not changing.

In MODE 6, fuel loading results in a continually changing core reactivity.

Boron concentration requirements (LCO 3.9.1, "Boron Concentration")

ensure that fuel movements are performed within the bounds of the safety analysis. An SDM demonstration is required during the first startup following operations that could have altered core reactivity (e.g., fuel movement, or CEA replacement, or shuffling).

CEOG STS B 3.1.2-3 Rev. 3.0, 03/31/04 1 6 San Onofre - Draft 3 Revision XXX Attachment 1, Volume 4, Rev. 0, Page 44 of 345

Attachment 1, Volume 4, Rev. 0, Page 45 of 345 Reactivity Balance (Digital) 2 B 3.1.2 3 6 BASES ACTIONS A.1 and A.2 Should an anomaly develop between measured and predicted core reactivity, an evaluation of the core design and safety analysis must be performed. Core conditions are evaluated to determine their consistency with input to design calculations. Measured core and process parameters are evaluated to determine that they are within the bounds of the safety analysis, and safety analysis calculational models are reviewed to verify that they are adequate for representation of the core conditions. The required Completion Time of 7 days is based on the low probability of a DBA occurring during this period, and allows sufficient time to assess the physical condition of the reactor and complete the evaluation of the core design and safety analysis.

Following evaluations of the core design and safety analysis, the cause of the reactivity anomaly may be resolved. If the cause of the reactivity anomaly is a mismatch in core conditions at the time of RCS boron concentration sampling, then a recalculation of the RCS boron concentration requirements may be performed to demonstrate that core reactivity is behaving as expected. If an unexpected physical change in the condition of the core has occurred, it must be evaluated and corrected, if possible. If the cause of the reactivity anomaly is in the calculation technique, then the calculational models must be revised to provide more accurate predictions. If any of these results are demonstrated and it is concluded that the reactor core is acceptable for continued operation, then the boron letdown curve may be renormalized, and power operation may continue. If operational restrictions or additional SRs are necessary to ensure the reactor core is acceptable for continued operation, then they must be defined.

The required Completion Time of 7 days is adequate for preparing whatever operating restrictions or Surveillances that may be required to allow continued reactor operation.

B.1 If the core reactivity cannot be restored to within the 1% k/k, the plant 4 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 LCO 3.1.1 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . If the SDM for MODE 3 is not met, then boration required by Required Action SR 3.1.1.1 would occur. The allowed Completion Time is reasonable, 7 A.1 based on operating experience, for reaching MODE 3 from full power conditions in an orderly manner and without challenging plant systems.

CEOG STS B 3.1.2-4 Rev. 3.0, 03/31/04 1 6 San Onofre - Draft 3 Revision XXX Attachment 1, Volume 4, Rev. 0, Page 45 of 345

Attachment 1, Volume 4, Rev. 0, Page 46 of 345 2

Reactivity Balance (Digital)

B 3.1.2 6 3

BASES SURVEILLANCE SR 3.1.2.1 6 REQUIREMENTS 3 Core reactivity is verified by periodic comparisons of measured and predicted RCS boron concentrations. The comparison is made considering that other core conditions are fixed or stable including CEA position, moderator temperature, fuel temperature, fuel depletion, xenon concentration, and samarium concentration. The Surveillance is performed prior to entering MODE 1 as an initial check on core conditions two 9

and design calculations at BOC. The SR is modified by three Notes. The first Note indicates that the normalization of predicted core reactivity to (if performed) may 8 the measured value must take place within the first 60 effective full power days (EFPD) after each fuel loading. This allows sufficient time for core conditions to reach steady state, but prevents operation for a large fraction of the fuel cycle without establishing a benchmark for the design calculations. The required subsequent Frequency of 31 EFPD, following the initial 60 EFPD after entering MODE 1, is acceptable, based on the TSTF-425-A INSERT 1 slow rate of core changes due to fuel depletion and the presence of other indicators (e.g., QPTR) for prompt indication of an anomaly. A Note, 9 "only required after 60 EFPD," is added to the Frequency column to allow this. Another Note indicates that the performance of SR 3.1.2.1 is not 6 required prior to entering MODE 2. This Note is required to allow a 3 MODE 2 entry to verify core reactivity because Applicability is for MODES 1 and 2.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 26, GDC 28, and GDC 29.

1 3

2. FSAR, Section [ ].

U Chapter 15 CEOG STS B 3.1.2-5 Revision XXX Rev. 3.0, 03/31/04 1 6 San Onofre - Draft 3 Attachment 1, Volume 4, Rev. 0, Page 46 of 345

Attachment 1, Volume 4, Rev. 0, Page 47 of 345 B 3.1.3 TSTF-425-A INSERT 1 10 The Frequency is controlled under the Surveillance Frequency Control Program.

Reviewer's Note-------------------------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of 5 Frequency in the Surveillance Requirement.

Insert Page B 3.1.3-5 Attachment 1, Volume 4, Rev. 0, Page 47 of 345

Attachment 1, Volume 4, Rev. 0, Page 48 of 345 JUSTIFICATION FOR DEVIATIONS ITS 3.1.3 BASES, REACTIVITY BALANCE

1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The headings for ISTS 3.1.2 (ITS 3.1.3) Bases include the parenthetical expression

"(Digital)." This identifying information is not included in the San Onofre Nuclear Generating Station (SONGS) ITS. This information is provided in the NUREG to assist in identifying the appropriate Specification to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific ITS implementation. SONGS Units 2 and 3 are digital plants; therefore analog requirements and specific labels that identify a requirement is digital are not required.

3. The ISTS contains bracketed information and/or values that are generic to all Combustion Engineering vintage plants. The brackets are removed and the proper plant specific information/value is provided. This is acceptable since the information/value is revised to reflect the current licensing basis.

4. Changes are made to use correct punctuation, correct typographical errors or to make corrections consistent with the Writers Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01.

5. This "Reviewers Note" is being deleted. The Reviewers Note is for the NRC reviewer during the NRC review and will not be part of the plant specific SONGS ITS.

6. The Specification/SR number has been changed to be consistent with the Specification number in the SONGS CTS. SONGS CTS contained two SDM Specifications (CTS 3.1.1, SDM in MODES 3 and 4, and CTS 3.1.2, SDM in MODE 5) which are being combined into one Specification (ITS 3.1.1), consistent with NUREG-1432. SCE has decided not to renumber the CTS to be consistent with the ISTS because by doing so would result in the unnecessary administrative burden of changing TS numbers in plant procedures.

7. The statement, "If the SDM for MODE 3 is not met, then boration required by SR 3.1.1.1 would occur" references the incorrect reference in Specification 3.1.1.

This statement is being changed to reference LCO 3.1.1 Required Action A.1 which is the actual requirement that requires boration when the SDM is not met.

8. This change is being made to be consistent with the actual wording of the Note in ISTS SR 3.1.2.1 (ITS SR 3.1.3.1). Also, the proposed wording (use of "may") is consistent with a similar description concerning normalization in the Applicable Safety Analyses section of the Bases.

9. Changes are made to be consistent with changes made to the Specification.

10. The Bases words changed by TSTF-425 have been modified to state "The Frequency is controlled under the Surveillance Frequency Control Program." The Surveillance Frequency Control Program provides the details for how to change the Frequencies, thus the TSTF-425 words concerning operating experience, equipment reliability, and plant risk is not always true for each of the Frequencies.

San Onofre Unit 2 and 3 Page 1 of 2 Attachment 1, Volume 4, Rev. 0, Page 48 of 345

Attachment 1, Volume 4, Rev. 0, Page 49 of 345 JUSTIFICATION FOR DEVIATIONS ITS 3.1.3 BASES, REACTIVITY BALANCE

11. The sentence is confusing in that the "R" in "RTP" is being used to also modify the term "moderator temperature". That is, the second part of the phrase is meant to be "rated" moderator temperature. To alleviate this confusion, the word "rated" has been added before the words "moderator temperature."

San Onofre Unit 2 and 3 Page 2 of 2 Attachment 1, Volume 4, Rev. 0, Page 49 of 345

Attachment 1, Volume 4, Rev. 0, Page 50 of 345 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 4, Rev. 0, Page 50 of 345

Attachment 1, Volume 4, Rev. 0, Page 51 of 345 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.1.3, REACTIVITY BALANCE There were no specific No Significant Hazards Considerations for this Specification.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 4, Rev. 0, Page 51 of 345

Attachment 1, Volume 4, Rev. 0, Page 52 of 345 ATTACHMENT 3 ITS 3.1.4, MODERATOR TEMPERATURE COEFFICIENT (MTC)

Attachment 1, Volume 4, Rev. 0, Page 52 of 345

, Volume 4, Rev. 0, Page 53 of 345 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 4, Rev. 0, Page 53 of 345

Attachment 1, Volume 4, Rev. 0, Page 54 of 345 ITS MTC A01 3.1.4 3.1 REACTIVITY CONTROL SYSTEMS 3.1.4 3.1.4 Moderator Temperature Coefficient (MTC)

LCO 3.1.4 LCO 3.1.4 The MTC shall be maintained within the limits specified in the COLR, and a maximum positive limit as specified below:

a. 0.5 E-4 k/k/EF when THERMAL POWER is # 70% RTP; and

b. 0.0 k/k/EF when THERMAL POWER is > 70% RTP.

Applicability APPLICABILITY: MODES 1 and 2 with Keff $ 1.0 M01 ACTION CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. MTC not within limits. A.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

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

SR 3.1.4.1 is not required to be performed A02 prior to entry into MODE 2.

SR 3.1.4.1 SR 3.1.4.1 Verify MTC within the upper limit. Prior to entering MODE 1 specified in the COLR after each fuel L01 loading AND (continued)

- - - - - - - - - - - - - - - -Note- - - - - - - - - - - - - - - - - - - -

Only required to be performed when MTC determined prior to entering MODE 1 is verified using adjusted predicted MTC. L01 Each fuel cycle within 14 effective full power days (EFPD) of reaching 40 EFPD core burnup SAN ONOFRE--UNIT 2 3.1-5 Amendment No. 127 Attachment 1, Volume 4, Rev. 0, Page 54 of 345

Attachment 1, Volume 4, Rev. 0, Page 55 of 345 ITS A01 MTC 3.1.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

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

1. SR 3.1.4.2 is not required to be A02 performed prior to entry into MODE 1 or 2.

2. Measured MTC values shall be extrapolated and compensated to RTP to LA01 permit direct comparison with the specified in the COLR negative limit. If the MTC is more negative than the COLR limit when extrapolated to the end of cycle, SR 3.1.4.2 may be repeated.

SR 3.1.4.2

3. Shutdown must occur prior to reducing Note the boron concentration below the A01 exceeding minimum allowable boron concentration at which MTC is projected to exceed the lower limit.

SR 3.1.4.2 SR 3.1.4.2 Verify MTC is within the lower limit Each fuel cycle specified in the COLR. within +14 effective full power days (EFPD) of peak L01 predicted boron concentration reaching 40 at rated EFPD core thermal power burnup AND Each fuel cycle within +30 EFPD L01 2

of -

3 of reaching expected core burnup SAN ONOFRE--UNIT 2 3.1-6 Amendment No. 127 Attachment 1, Volume 4, Rev. 0, Page 55 of 345

Attachment 1, Volume 4, Rev. 0, Page 56 of 345 ITS MTC A01 3.1.4 3.1 REACTIVITY CONTROL SYSTEMS 3.1.4 3.1.4 Moderator Temperature Coefficient (MTC)

LCO 3.1.4 LCO 3.1.4 The MTC shall be maintained within the limits specified in the COLR, and a maximum positive limit as specified below:

a. 0.5 E-4 k/k/EF when THERMAL POWER is # 70% RTP; and

b. 0.0 k/k/EF when THERMAL POWER is > 70% RTP.

Applicability APPLICABILITY: MODES 1 and 2 with Keff $ 1.0 M01 ACTION CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. MTC not within limits. A.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

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

SR 3.1.4.1 is not required to be performed A02 prior to entry into MODE 2.

SR 3.1.4.1 SR 3.1.4.1 Verify MTC within the upper limit. Prior to entering MODE 1 specified in the COLR after each fuel L01 loading AND (continued)

- - - - - - - - - - - - - - - -Note- - - - - - - - - - - - - - - - - - - -

Only required to be performed when MTC determined prior to entering MODE 1 is verified using adjusted predicted MTC. L01 Each fuel cycle within 14 effective full power days (EFPD) of reaching 40 EFPD core burnup SAN ONOFRE--UNIT 3 3.1-5 Amendment No. 116 Attachment 1, Volume 4, Rev. 0, Page 56 of 345

Attachment 1, Volume 4, Rev. 0, Page 57 of 345 ITS A01 MTC 3.1.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

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

1. SR 3.1.4.2 is not required to be A02 performed prior to entry into MODE 1 or 2.

2. Measured MTC values shall be extrapolated and compensated to RTP to LA01 permit direct comparison with the specified in the COLR negative limit. If the MTC is more negative than the COLR limit when extrapolated to the end of cycle, SR 3.1.4.2 may be repeated.

SR 3.1.4.2

3. Shutdown must occur prior to reducing Note the boron concentration below the A01 exceeding minimum allowable boron concentration at which MTC is projected to exceed the lower limit.

SR 3.1.4.2 SR 3.1.4.2 Verify MTC is within the lower limit Each fuel cycle specified in the COLR. within +14 effective full power days (EFPD) of peak L01 predicted boron concentration reaching 40 at rated EFPD core thermal power burnup AND Each fuel cycle within +30 EFPD L01 2

of -

3 of reaching expected core burnup SAN ONOFRE--UNIT 3 3.1-6 Amendment No. 116 Attachment 1, Volume 4, Rev. 0, Page 57 of 345

Attachment 1, Volume 4, Rev. 0, Page 58 of 345 DISCUSSION OF CHANGES ITS 3.1.4, MODERATOR TEMPERATURE COEFFICIENT (MTC)

ADMINISTRATIVE CHANGES A01 In the conversion of the San Onofre Nuclear Generating Station (SONGS)

Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1432, Rev. 3.0, "Standard Technical Specifications Combustion Engineering Plants" (ISTS) and additional approved Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS SR 3.1.4.1 contains a Note that allows entry into MODE 2 without the SR having to be performed. CTS SR 3.1.4.2 contains a Note that allows entry into MODE 1 or 2 without the SR having to be performed ITS SR 3.1.4.1 and ITS SR 3.1.4.2 do not contain these Notes. This changes the CTS by deleting these Notes.

The purpose of the Notes is to allow the plant to enter the MODE of Applicability without performing the required Surveillances. This change is acceptable because the CTS as well as the ITS SR 3.1.4.1 and SR 3.1.4.2 Frequencies are written to allow entry into MODE 1 or MODE 2, as applicable. This serves the same purpose as the Notes and is described in CTS and ITS SR 3.0.4. This change is designated as administrative because it eliminates a CTS provision which is not required because it is already allowed by the SR Frequency.

MORE RESTRICTIVE CHANGES M01 CTS 3.1.4 requires MTC to be within limits in MODES 1 and 2 with keff > 1.0.

ITS 3.1.4 requires MTC to be within limits in MODES 1 and 2. This changes the CTS by expanding the Applicability of the MTC requirements to include MODE 2 with keff < 1.0.

The purpose of the CTS 3.1.4 is to ensure that MTC is within limits. This change is acceptable because the ITS requires MTC to apply at all times in MODES 1 and 2 to help ensure MTC is maintained. This change is designated as more restrictive because it expands the Applicability for MTC.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 4 - Removal of LCO, SR, or other TS requirement to the LCS, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance San Onofre Unit 2 and 3 Page 1 of 3 Attachment 1, Volume 4, Rev. 0, Page 58 of 345

Attachment 1, Volume 4, Rev. 0, Page 59 of 345 DISCUSSION OF CHANGES ITS 3.1.4, MODERATOR TEMPERATURE COEFFICIENT (MTC)

Frequency Control Program) CTS SR 3.1.4.2 is modified by a Note that requires the measured MTC values to be extrapolated and compensated to RTP (Rated Thermal Power) to permit direct comparison with the negative limit. ITS SR 3.1.4.2 does not contain this Note; however, the requirements of the Note are contained in the Bases. This changes the CTS by deleting this Note and relocating these details to the Bases.

The removal of these details that require the measured MTC values to be extrapolated and compensated to RTP to permit direct comparison with the negative limit, from the Technical Specification is acceptable since this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. This change is acceptable because this type of procedural detail will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specifications Bases Control Program in Chapter 5. This change is designated as a less restrictive removal of detail change because procedural details for performing Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 7 - Relaxation of Surveillance Frequency) CTS SR 3.1.4.1 requires the MTC be verified within the upper limit prior to entering MODE 1 after each fuel loading. CTS SR 3.1.4.2 requires MTC to be verified within the lower limit as specified in the COLR each fuel cycle within +/-14 EFPD of peak predicted boron concentration at rated thermal power and each fuel cycle within +/- 30 EFPD of of expected core burnup. ITS 3.1.4.1 requires the MTC to be verified within the upper limit "as specified in the COLR" prior to entering MODE 1 after each fuel loading and "each fuel cycle within 14 EFPD of reaching 40 EFPD core burnup."

The SR is modified by a Note that states the SR is only required to be performed when MTC is determined prior to entering MODE 1 using adjusted predicted MTC. ITS SR 3.1.4.2 requires the MTC to be verified within the lower limit specified in the COLR each fuel cycle within 14 EFPD of "reaching 40 EFPD core burnup" and each fuel cycle within 30 EFPD of "reaching" of expected core burnup. This changes the CTS by requiring verification that MTC is within the upper limit each fuel cycle within 14 EFPD of reaching 40 EFPD of core burnup, but only when the MTC determined prior to entering MODE 1 is verified using predicted MTC as adjusted for actual RCS boron concentration. Minor editorial changes are made to the Surveillances to properly reference the limit specified in the COLR.

While TSTF-486 did not specifically change the Frequency in the ITS to verifying MTC within 14 EFPD of a required core burnup specified in SR 3.1.4.2, it is included in this change. TSTF-486 is based on this Frequency. Also, extraneous verbiage in SR 3.1.4.2 Frequency is being deleted to be consistent with the NUREG-1432 and TSTF-486. Deletion of this extraneous information is an administrative change and is also included as part of this change.

This change is consistent with TSTF-486 which is based on WCAP-16011-P, Rev. 0, "Startup Test Activity Reduction Program," proposed changes to San Onofre Unit 2 and 3 Page 2 of 3 Attachment 1, Volume 4, Rev. 0, Page 59 of 345

Attachment 1, Volume 4, Rev. 0, Page 60 of 345 DISCUSSION OF CHANGES ITS 3.1.4, MODERATOR TEMPERATURE COEFFICIENT (MTC) pressurized water reactor reload startup testing to reduce testing operations and testing time while achieving the following objectives: (1) ensure that the core can be operated as designed, and (2) employ normal operating procedures in the startup evolution. The Topical Report was approved on January 14, 2005. One of the proposed changes relates to the verification of Moderator Temperature Coefficient (MTC) which is depicted in this change. The beginning of cycle verification of MTC is required prior to entering MODE 1. For fuel cycles that meet the applicability requirements given in WCAP-16011, the verification prior to entering MODE 1 may be made using the predicted MTC as adjusted for the actual boron concentration. When this approach is used, an additional measurement of MTC is required within 7 EFPD of reaching 40 EFPD.

Implementation of the Startup Test Activity Reduction Program shortens the time required to perform startup testing, allowing a quicker return to power generation.

However, SCE has already been licensed to use a 14 day EFPD window, as documented in the NRC Safety Evaluation for Amendments 127 (Unit 2) and 116 (Unit 3) (which are the original SONGS ITS amendments).

WCAP-16011-P describes a method to reduce the time required for startup testing. To this end, the Topical Report (TR) justifies the elimination of certain startup testing requirements, including the control element assembly (CEA) worth and isothermal temperature coefficient (ITC) measurements at hot zero power (HZP). The TR also proposed to substitute the measured value of the moderator temperature coefficient (MTC) at HZP with an alternate MTC value consisting of the predicted (calculated) MTC as adjusted for the measured critical boron concentration (CBC) at HZP. An ITC measurement at intermediate to hot full power (HFP) is also added. This method may be applied to cores that are well characterized by an existing database, using applicability requirements described in WCAP-16011.

Southern California Edison (SCE) has reviewed the CLIIP. This review included a review of the NRC staffs evaluation, as well as the supporting information provided to support TSTF-486 Revision 2. SCE has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to SONGS Units 2 and 3 and have justified this amendment for the incorporation of the changes to the SONGS Units 2 and 3 TS.

However, consistent with the statement above concerning SR 3.1.4.1 changes, the currently licensed 14 day and 30 day windows in SRs 3.1.4.2 are being retained.

This change is classified as less restrictive because it proposes to substitute the measured value of the MTC at HZP with an alternate MTC value consisting of the predicted (calculated) MTC as adjusted for the measured critical boron concentration at HZP consistent with the topical report to reduce plant startup by reducing testing.

San Onofre Unit 2 and 3 Page 3 of 3 Attachment 1, Volume 4, Rev. 0, Page 60 of 345

Attachment 1, Volume 4, Rev. 0, Page 61 of 345 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 4, Rev. 0, Page 61 of 345

Attachment 1, Volume 4, Rev. 0, Page 62 of 345 2

MTC (Digital)

U2/U3 CTS 3.1.3 4 4

3.1 REACTIVITY CONTROL SYSTEMS 4 2 3.1.3 Moderator Temperature Coefficient (MTC) (Digital) 4 LCO 3.1.4 LCO 3.1.3 The MTC shall be maintained within the limits specified in the COLR, and 4 4 a maximum positive limit as specified below:

3

a. [0.5 E-4 k/k/F] when THERMAL POWER is 70% RTP and

b. [0.0 k/k/F] when THERMAL POWER is > 70% RTP. 3 Applicability APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. MTC not within limits. A.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4.1 SR 3.1.3.1 Verify MTC is within the upper limit. Prior to entering 4 TSTF-4 MODE 1 after 486-A specified in the COLR each fuel loading AND TSTF-

NOTE------------------------ 486-A Only required to be performed when MTC determined prior to entering MODE 1 is verified using adjusted predicted MTC.

5 14 Each fuel cycle within 7 effective full power days (EFPD) of reaching 40 EFPD core burnup CEOG STS 3.1.3-1 Rev. 3.0, 03/31/04 1 4 San Onofre - Draft 4 Amendment XXX Attachment 1, Volume 4, Rev. 0, Page 62 of 345

Attachment 1, Volume 4, Rev. 0, Page 63 of 345 2

MTC (Digital)

U2/U3 CTS 3.1.3 4 4

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.1.4.2 4 SR 3.1.3.2 -------------------------------NOTE------------------------------

4 If the MTC is more negative than the COLR limit TSTF-when extrapolated to the end of cycle, SR 3.1.3.2 4 486-A may be repeated. Shutdown must occur prior to 4 specified in the COLR exceeding the minimum allowable boron concentration at which MTC is projected to exceed the lower limit.

5 Verify MTC is within the lower limit. Each fuel cycle 14 within 7 effective TSTF-specified in the COLR full power days 486-A (EFPD) of reaching 40 EFPD core burnup AND Each fuel cycle 30 5 within 7 EFPD of reaching 2/3 of expected core burnup CEOG STS 3.1.3-2 Rev. 3.0, 03/31/04 1 4 San Onofre - Draft 4 Amendment XXX Attachment 1, Volume 4, Rev. 0, Page 63 of 345

Attachment 1, Volume 4, Rev. 0, Page 64 of 345 JUSTIFICATION FOR DEVIATIONS ITS 3.1.4, MODERATOR TEMPERATURE COEFFICIENT (MTC)

1. Changes are made (additions, deletions, and/or changes) to the ISTS which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The headings for ISTS 3.1.3 (ITS 3.1.4) include the parenthetical expression

"(Digital)." This identifying information is not included in the San Onofre Nuclear Generating Station (SONGS) ITS. This information is provided in the NUREG to assist in identifying the appropriate Specification to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific ITS implementation. SONGS Units 2 and 3 are digital plants; therefore analog requirements and specific labels that identify a requirement is digital are not required.

3. The ISTS contains bracketed information and/or values that are generic to all Combustion Engineering vintage plants. The brackets are removed and the proper plant specific information/value is provided. This is acceptable since the information/value is revised to reflect the current licensing basis.

4. The Specification/SR number has been changed to be consistent with the Specification number in the SONGS CTS. SONGS CTS contained two SDM Specifications (CTS 3.1.1, SDM in MODES 3 and 4, and CTS 3.1.2, SDM in MODE 5) which are being combined into one Specification (ITS 3.1.1), consistent with NUREG-1432. SCE has decided not to renumber the CTS to be consistent with the ISTS because by doing so would result in the unnecessary administrative burden of changing TS numbers in plant procedures.

5. The limit in the second SR Frequency for ISTS SR 3.1.3.1 (ITS SR 3.1.4.1) has been changed to 14 EFPD, consistent with the allowance already in the SONGS CTS for SR 3.1.4.2. In addition, the times have been changed from 7 EFPD in the two Frequencies for ISTS SR 3.1.3.2 (ITS SR 3.1.4.2) to 14 EFPD and 30 EFPD, respectively, consistent with the values in the SONGS CTS. These values were approved by the NRC during the ITS conversion in Amendments 127 (Unit 2) and 116 (Unit 3).

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 4, Rev. 0, Page 64 of 345

Attachment 1, Volume 4, Rev. 0, Page 65 of 345 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 4, Rev. 0, Page 65 of 345

Attachment 1, Volume 4, Rev. 0, Page 66 of 345 2

MTC (Digital)

B 3.1.3 5 4

B 3.1 REACTIVITY CONTROL SYSTEMS B 3.1.3 Moderator Temperature Coefficient (MTC) (Digital) 5 2 4

BASES BACKGROUND According to GDC 11 (Ref. 1), the reactor core and its interaction with the Reactor Coolant System (RCS) must be designed for inherently stable power operation, even in the possible event of an accident. In particular, the net reactivity feedback in the system must compensate for any unintended reactivity increases.

The MTC relates a change in core reactivity to a change in reactor coolant temperature. A positive MTC means that reactivity increases with increasing moderator temperature; conversely, a negative MTC means that reactivity decreases with increasing moderator temperature. The reactor is designed to operate with a negative MTC over the largest possible range of fuel cycle operation. Therefore, a coolant temperature increase will cause a reactivity decrease, so that the coolant temperature tends to return toward its initial value. Reactivity increases that cause a coolant temperature increase will thus be self limiting, and stable power operation will result. The same characteristic is true when the MTC is TSTF-positive and coolant temperature decreases occur. 486-A reload design MTC values are predicted at selected burnups during the safety 1 process evaluation analysis and are confirmed to be acceptable by measurements. Both initial and reload cores are designed so that the beginning of cycle (BOC) MTC is less positive than that allowed by the LCO. The actual value of the MTC is dependent on core characteristics such as fuel loading and reactor coolant soluble boron concentration.

The core design may require additional fixed distributed poisons (lumped burnable poison assemblies) to yield an MTC at the BOC within the range analyzed in the plant accident analysis. The end of cycle (EOC) MTC is also limited by the requirements of the accident analysis. Fuel cycles that are designed to achieve high burnups or that have changes to other characteristics are evaluated to ensure that the MTC does not exceed the EOC limit.

APPLICABLE The acceptance criteria for the specified MTC are:

SAFETY ANALYSES a. The MTC values must remain within the bounds of those used in the accident analysis (Ref. 2) and

b. The MTC must be such that inherently stable power operations result during normal operation and during accidents, such as overheating and overcooling events.

CEOG STS B 3.1.3-1 Revision XXX Rev. 3.0, 03/31/04 1 5 San Onofre - Draft 4

Attachment 1, Volume 4, Rev. 0, Page 66 of 345

Attachment 1, Volume 4, Rev. 0, Page 67 of 345 2

MTC (Digital)

B 3.1.3 5 4

BASES APPLICABLE SAFETY ANALYSES (continued)

Reference 2 contains analyses of accidents that result in both overheating and overcooling of the reactor core. MTC is one of the controlling parameters for core reactivity in these accidents. Both the most positive value and most negative value of the MTC are important to safety, and both values must be bounded. Values used in the analyses consider worst case conditions, such as very large soluble boron concentrations, to ensure the accident results are bounding (Ref. 3).

Accidents that cause core overheating, either by decreased heat removal or increased power production, must be evaluated for results when the MTC is positive. Reactivity accidents that cause increased power production include the control element assembly (CEA) withdrawal transient from either zero or full THERMAL POWER. The limiting overheating event relative to plant response is based on the maximum difference between core power and steam generator heat removal during a transient. The most limiting event with respect to a positive MTC is a 1

CEA withdrawal accident from zero power, also referred to as a startup accident (Ref. 4).

Accidents that cause core overcooling must be evaluated for results when the MTC is most negative. The event that produces the most rapid cooldown of the RCS, and is therefore the most limiting event with respect to the negative MTC, is a steam line break (SLB) event.

Following the reactor trip for the postulated EOC SLB event, the large moderator temperature reduction combined with the large negative MTC may produce reactivity increases that are as much as the shutdown reactivity. When this occurs, a substantial fraction of core power is produced with all CEAs inserted, except the most reactive one, which is assumed withdrawn. Even if the reactivity increase produces slightly subcritical conditions, a large fraction of core power may be produced through the effects of subcritical neutron multiplication.

A measurement is conducted at conditions MTC values are bounded in reload safety evaluations assuming steady when the core reaches state conditions at BOC and EOC. A middle of cycle (MOC) 6 approximately 2/3 of measurement is conducted at conditions when the RCS boron expected core burnup. concentration reaches approximately 300 ppm. The measured value may be extrapolated to project the EOC value, in order to confirm reload design predictions.

The MTC satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

1 4 CEOG STS B 3.1.3-2 Revision XXX Rev. 3.0, 03/31/04 San Onofre - Draft 4

Attachment 1, Volume 4, Rev. 0, Page 67 of 345

Attachment 1, Volume 4, Rev. 0, Page 68 of 345 MTC (Digital) 2 B 3.1.3 5 4

positive and negative limits in 5 BASES 4 TSTF-LCO LCO 3.1.3 requires the MTC to be within the specified limits of the COLR 486-A to ensure the core operates within the assumptions of the accident 1

design process analysis. During the reload core safety evaluation, the MTC is analyzed to determine that its values remain within the bounds of the original TSTF-The positive MTC limit in the accident analysis during operation. The limit on a positive MTC ensures 486-A COLR that core overheating accidents will not violate the accident analysis assumptions. The negative MTC limit for EOC specified in the COLR ensures that core overcooling accidents will not violate the accident analysis assumptions. TSTF-486-A INSERT 1 MTC is a core physics parameter determined by the fuel and fuel cycle design and cannot be easily controlled once the core design is fixed.

TSTF-INSERT 2 During operation, therefore, the LCO can only be ensured through 486-A and adjustments to CEA measurement. The surveillance checks at BOC and MOC on an MTC position and boron provide confirmation that the MTC is behaving as anticipated, so that the concentration acceptance criteria are met.

APPLICABILITY In MODE 1, the limits on the MTC must be maintained to ensure that any accident initiated from THERMAL POWER operation will not violate the design assumptions of the accident analysis. In MODE 2, the limits must also be maintained to ensure startup and subcritical accidents, such as the uncontrolled CEA assembly or group withdrawal, will not violate the assumptions of the accident analysis. In MODES 3, 4, 5, and 6, this LCO is not applicable, since no Design Basis Accidents (DBAs) using the MTC as an analysis assumption are initiated from these MODES. However, the variation of the MTC, with temperature in MODES 3, 4, and 5, for DBAs initiated in MODES 1 and 2, is accounted for in the subject accident analysis. The variation of the MTC, with temperature assumed in the safety analysis, is accepted as valid once the BOC and MOC measurements are used for normalization.

ACTIONS A.1 MTC is a function of the fuel and fuel cycle designs, and cannot be controlled directly once the designs have been implemented in the core.

If MTC exceeds its limits, the reactor must be placed in MODE 3. This eliminates the potential for violation of the accident analysis bounds. The associated Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, considering the probability of an accident occurring during the time period that would require an MTC value within the LCO limits, and the time for reaching MODE 3 from full power conditions in an orderly manner and without challenging plant systems.

CEOG STS B 3.1.3-3 Revision XXX Rev. 3.0, 03/31/04 1 5 San Onofre - Draft 4

Attachment 1, Volume 4, Rev. 0, Page 68 of 345

Attachment 1, Volume 4, Rev. 0, Page 69 of 345 B 3.1.4 TSTF-486-A INSERT 1 The MTC limit specified in the LCO is the maximum positive MTC value approved in the plant's licensing basis and ensures that the reactor operates with a negative MTC over the largest possible range of fuel cycle operation. The cycle-specific MTC limit specified in the COLR must be equal to or less positive than the MTC limit specified in the LCO.

TSTF-486-A INSERT 2 Limited control of MTC can be achieved by adjusting CEA position and boron concentration.

Insert Page B 3.1.3-3 Attachment 1, Volume 4, Rev. 0, Page 69 of 345

Attachment 1, Volume 4, Rev. 0, Page 70 of 345 2

MTC (Digital)

B 3.1.3 5 4

BASES 4 5

SURVEILLANCE SR 3.1.3.1 and SR 3.1.3.2 REQUIREMENTS The SRs for measurement of the MTC at the beginning and middle of each fuel cycle provide for confirmation of the limiting MTC values. The MTC changes smoothly from most positive (least negative) to most negative value during fuel cycle operation, as the RCS boron TSTF-INSERT 3 concentration is reduced to compensate for fuel depletion. The 486-A requirement for measurement prior to operation > 5% RTP satisfies the confirmatory check on the most positive (least negative) MTC value. The EFPD 14 requirement for measurement, within 7 days after reaching 40 effective 7 TSTF-EFPD full power days and a 2/3 core burnup, satisfies the confirmatory check of 7 486-A the most negative MTC value. The measurement is performed at any at a core burnup within THERMAL POWER so that the projected EOC MTC may be evaluated 30 EFPD of before the reactor actually reaches the EOC condition. MTC values may be extrapolated and compensated to permit direct comparison to the TSTF-486-A specified MTC limits. specified in the COLR 4

SR 3.1.3.2 is modified by a Note, which indicates that if extrapolated MTC 5 is more negative than the EOC COLR limit, the Surveillance may be repeated, and that shutdown must occur prior to exceeding the minimum allowable boron concentration at which MTC is projected to exceed the lower limit. An engineering evaluation is performed if the extrapolated value of MTC exceeds the Specification limits.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 11.

2. FSAR, Section [ ]. 15.0 U

3. FSAR, Section [ ]. 15.4 1 3

4. FSAR, Section [ ]. 15.4.1.1 TSTF-486-A

5. WCAP-16011-P-A, Rev. 0, "Startup Test Activity Reduction Program," dated February 2005.

CEOG STS B 3.1.3-4 Rev. 3.0, 03/31/04 1 San Onofre - Draft Revision XXX 4

Attachment 1, Volume 4, Rev. 0, Page 70 of 345

Attachment 1, Volume 4, Rev. 0, Page 71 of 345 B 3.1.4 TSTF- INSERT 3 486-A

REVIEWERS NOTE ------------------------------------------

The following Bases and the second Frequency of SR 3.1.3.1 are only applicable to plants that 4 adopt WCAP-16011 (Reference 5).

3

[ For fuel cycles that meet the applicability requirements in Reference 5, and specifically the acceptance criteria that must be met in order to substitute the measured value of MTC at hot 4 5 zero power (HZP) with an alternate MTC value, SR 3.1.3.1 may be met prior to entering MODE 1 after each fuel loading by confirmation that the predicted MTC, when adjusted for the measured RCS boron concentration, is within the most positive (least negative) MTC limit specified in the COLR. If this adjusted predicted MTC value is used to meet the SR prior to entering MODE 1, a confirmation by measurement that MTC is within the upper MTC limit must 7 14 be performed in MODE 1 within 7 Effective Full Power Days (EFPD) after reaching 40 EFPD of core burnup. The applicability requirements in Reference 5 ensure core designs are not significantly different from those used to benchmark predictions and require that the measured RCS boron concentration meets specific test criteria. This provides assurance that the MTC obtained from the adjusted predicted MTC is accurate.

For fuel cycles that do not meet the applicability requirements in Reference 5, the verification of MTC required prior to entering MODE 1 after each fuel loading is performed by calculation of the MTC based on measurement of the isothermal temperature coefficient. In this case, 14 7 measurement of MTC within 7 EFPD after reaching 40 EFPD of core burnup is not required.] 3 Insert Page B 3.1.3-4 Attachment 1, Volume 4, Rev. 0, Page 71 of 345

Attachment 1, Volume 4, Rev. 0, Page 72 of 345 JUSTIFICATION FOR DEVIATIONS ITS 3.1.4 BASES, MODERATOR TEMPERATURE COEFFICIENT (MTC)

1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The headings for ISTS 3.1.3 (ITS 3.1.4) Bases include the parenthetical expression

"(Digital)." This identifying information is not included in the San Onofre Nuclear Generating Station (SONGS) ITS. This information is provided in the NUREG to assist in identifying the appropriate Specification to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific ITS implementation. SONGS Units 2 and 3 are digital plants; therefore analog requirements and specific labels that identify a requirement is digital are not required

3. The ISTS contains bracketed information and/or values that are generic to all Combustion Engineering vintage plants. The brackets are removed and the proper plant specific information/value is provided. This is acceptable since the information/value is revised to reflect the current licensing basis.

4. This "Reviewers Note" is being deleted. The Reviewers Note is for the NRC reviewer during the NRC review and will not be part of the plant specific SONGS ITS.

5. The Specification/SR number has been changed to be consistent with the Specification number in the SONGS CTS. SONGS CTS contained two SDM Specifications (CTS 3.1.1, SDM in MODES 3 and 4, and CTS 3.1.2, SDM in MODE 5) which are being combined into one Specification (ITS 3.1.1), consistent with NUREG-1432. SCE has decided not to renumber the CTS to be consistent with the ISTS because by doing so would result in the unnecessary administrative burden of changing TS numbers in plant procedures.

6. The performance of this measurement is at approximately 2/3 of expected core burnup, as specified in the last Frequency of ISTS SR 3.1.3.2 (ITS SR 3.1.4.2), not at MOC (300 ppm). Therefore, the words have been changed to be consistent with the actual SR Frequency requirement.

7. Changes have been made to be consistent with the changes made to the Specification.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 4, Rev. 0, Page 72 of 345

Attachment 1, Volume 4, Rev. 0, Page 73 of 345 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 4, Rev. 0, Page 73 of 345

Attachment 1, Volume 4, Rev. 0, Page 74 of 345 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.1.4, MODERATOR TEMPERATURE COEFFICIENT (MTC)

There were no specific No Significant Hazards Considerations for this Specification.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 4, Rev. 0, Page 74 of 345

Attachment 1, Volume 4, Rev. 0, Page 75 of 345 ATTACHMENT 4 ITS 3.1.5, CONTROL ELEMENT ASSEMBLY (CEA) ALIGNMENT Attachment 1, Volume 4, Rev. 0, Page 75 of 345

, Volume 4, Rev. 0, Page 76 of 345 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 4, Rev. 0, Page 76 of 345

Attachment 1, Volume 4, Rev. 0, Page 77 of 345 A01 CEA Alignment ITS 3.1.5 3.1 REACTIVITY CONTROL SYSTEMS .

3.1.5 3.1.5 Control Element Assembly (CEA) Alignment AND New paragraph A02 LCO 3.1.5 LCO 3.1.5 All full length CEAs shall be OPERABLE and all full and part length CEAs shall be aligned to within 7 inches of all other CEAs in its group.

(indicated position) their respective groups Applicability APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME action to reduce ACTION A A. One regulating CEA A.1 Initiate THERMAL 15 minutes A03 trippable and POWER reduction in A02 misaligned from its accordance with COLR group by > 7 inches. requirements.

AND CEA alignment A.2.1 Restore the 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months misaligned CEA(s) to LA02 within 7 inches of its group.

OR (continued)

SAN ONOFRE--UNIT 2 3.1-7 Amendment No. 127,200 Attachment 1, Volume 4, Rev. 0, Page 77 of 345

Attachment 1, Volume 4, Rev. 0, Page 78 of 345 CEA Alignment ITS A01 3.1.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. (continued) A.2.2 Align the remainder 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of the CEAs in the group to within 7 inches of the misaligned CEA(s) while maintaining the LA02 insertion limit of LCO 3.1.7, "Regulating Control Element Assembly (CEA) Insertion Limits."

action to reduce ACTION B B. One shutdown CEA B.1 Initiate THERMAL 15 minutes A03 trippable and POWER reduction in A02 misaligned from its accordance with COLR group by > 7 inches. requirements.

AND CEA alignment B.2 Restore the 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months LA02 misaligned CEA(s) to within 7 inches of its group.

(continued)

SAN ONOFRE--UNIT 2 3.1-8 Amendment No. 127,200 Attachment 1, Volume 4, Rev. 0, Page 78 of 345

Attachment 1, Volume 4, Rev. 0, Page 79 of 345 CEA Alignment A01 ITS 3.1.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME action to reduce ACTION C C. One part length CEA C.1 Initiate THERMAL 15 minutes A03 misaligned from its POWER reduction in group by > 7 inches. accordance with COLR requirements.

AND CEA alignment C.2.1 Restore the 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months misaligned CEA(s) to LA02 within 7 inches of its group.

OR C.2.2 Align the remainder 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months LA02 of the CEAs in the group to within 7 inches of the misaligned CEA(s),

while maintaining the insertion limit of LCO 3.1.8, "Part Length Regulating Control Element Assembly (CEA)

Insertion Limits."

(continued)

SAN ONOFRE--UNIT 2 3.1-9 Amendment No. 127 Attachment 1, Volume 4, Rev. 0, Page 79 of 345

Attachment 1, Volume 4, Rev. 0, Page 80 of 345 A01 CEA Alignment ITS 3.1.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION D D. Required Action and D.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, B, or C not met.

OR or more s One full length CEA M01 untrippable. A02 inoperable OR Two or More than one full s A04 A02 length CEA trippable, but misaligned from any other CEA in its group by > 7 inches.

OR Two or More than one part s A04 length CEA misaligned from any other CEA in its group by > 7 inches.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY indicated SR 3.1.5.1 SR 3.1.5.1 Verify the position of each full and part 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months A05 LA01 length CEA is within 7 inches of all other CEAs in its group.

(continued)

In accordance with the Surveillance Frequency Control Program SAN ONOFRE--UNIT 2 3.1-10 Amendment No. 127 Attachment 1, Volume 4, Rev. 0, Page 80 of 345

Attachment 1, Volume 4, Rev. 0, Page 81 of 345 A01 CEA Alignment ITS 3.1.5 SURVEILLANCE REQUIREMENTS (continued)

SR 3.1.5.2 Not used. SURVEILLANCE FREQUENCY SR 3.1.5.2 Verify that, for each CEA, its OPERABLE CEA 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months See ITS position indicator channels indicate within 3.1.15 5 inches of each other.

SR 3.1.5.3 SR 3.1.5.3 Verify full length CEA freedom of movement 92 days (trippability) by moving each individual LA01 full length CEA that is not fully inserted In accordance with the in the core at least 5 inches. Surveillance Frequency SR 3.1.5.4 Not used. Control Program SR 3.1.5.4 Perform a CHANNEL FUNCTIONAL TEST of each 24 months See ITS 3.1.15 reed switch position transmitter channel.

SR 3.1.5.5 SR 3.1.5.5 Verify each full length CEA drop time and Prior to the the arithmetic average of all full length first reactor CEA drop times is within at least one of criticality, the limit sets: after each removal of the Set Average (sec) Individual (sec) reactor head I # 3.0 # 3.2 II # 3.2 # 3.4 III # 3.4 # 3.6 SR 3.1.5.6 For each CEA drop time measurement Prior to performed under SR 3.1.5.5, verify that the reactor L01 appropriate CPC and COLSS addressable criticality constant adjustments have been made.

SAN ONOFRE--UNIT 2 3.1-11 Amendment No. 127 Attachment 1, Volume 4, Rev. 0, Page 81 of 345

Attachment 1, Volume 4, Rev. 0, Page 82 of 345 ITS A01 CEA Alignment 3.1.5 3.1 REACTIVITY CONTROL SYSTEMS .

3.1.5 3.1.5 Control Element Assembly (CEA) Alignment AND New paragraph A02 LCO 3.1.5 LCO 3.1.5 All full length CEAs shall be OPERABLE and all full and part length CEAs shall be aligned to within 7 inches of all other CEAs in its group.

(indicated position) their respective groups Applicability APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME action to reduce ACTION A A. One regulating CEA A.1 Initiate THERMAL 15 minutes A03 trippable and POWER reduction in A02 misaligned from its accordance with COLR group by > 7 inches. requirements.

AND CEA alignment A.2.1 Restore the 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months misaligned CEA(s) to LA02 within 7 inches of its group.

OR (continued)

SAN ONOFRE--UNIT 3 3.1-7 Amendment No. 116,191 Attachment 1, Volume 4, Rev. 0, Page 82 of 345

Attachment 1, Volume 4, Rev. 0, Page 83 of 345 CEA Alignment ITS A01 3.1.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. (continued) A.2.2 Align the remainder 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of the CEAs in the group to within 7 inches of the misaligned CEA(s) while maintaining the LA02 insertion limit of LCO 3.1.7, "Regulating Control Element Assembly (CEA) Insertion Limits."

action to reduce ACTION B B. One shutdown CEA B.1 Initiate THERMAL 15 minutes A03 trippable and POWER reduction in A02 misaligned from its accordance with COLR group by > 7 inches. requirements.

AND CEA alignment B.2 Restore the 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months LA02 misaligned CEA(s) to within 7 inches of its group.

(continued)

SAN ONOFRE--UNIT 3 3.1-8 Amendment No. 116,191 Attachment 1, Volume 4, Rev. 0, Page 83 of 345

Attachment 1, Volume 4, Rev. 0, Page 84 of 345 CEA Alignment A01 ITS 3.1.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME action to reduce ACTION C C. One part length CEA C.1 Initiate THERMAL 15 minutes A03 misaligned from its POWER reduction in group by > 7 inches. accordance with COLR requirements.

AND CEA alignment C.2.1 Restore the 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months misaligned CEA(s) to LA02 within 7 inches of its group.

OR C.2.2 Align the remainder 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months LA02 of the CEAs in the group to within 7 inches of the misaligned CEA(s),

while maintaining the insertion limit of LCO 3.1.8, "Part Length Regulating Control Element Assembly (CEA)

Insertion Limits."

(continued)

SAN ONOFRE--UNIT 3 3.1-9 Amendment No. 116 Attachment 1, Volume 4, Rev. 0, Page 84 of 345

Attachment 1, Volume 4, Rev. 0, Page 85 of 345 A01 CEA Alignment ITS 3.1.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION D D. Required Action and D.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, B, or C not met.

OR or more s One full length CEA M01 untrippable.

A02 inoperable OR Two or More than one full s A04 A02 length CEA trippable, but misaligned from any other CEA in its group by > 7 inches.

OR Two or More than one part s A04 length CEA misaligned from any other CEA in its group by > 7 inches.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY indicated SR 3.1.5.1 SR 3.1.5.1 Verify the position of each full and part 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months A05 LA01 length CEA is within 7 inches of all other CEAs in its group.

(continued)

In accordance with the Surveillance Frequency Control Program SAN ONOFRE--UNIT 3 3.1-10 Amendment No. 116 Attachment 1, Volume 4, Rev. 0, Page 85 of 345

Attachment 1, Volume 4, Rev. 0, Page 86 of 345 A01 CEA Alignment ITS 3.1.5 SURVEILLANCE REQUIREMENTS (continued)

SR 3.1.5.2 Not used. SURVEILLANCE FREQUENCY SR 3.1.5.2 Verify that, for each CEA, its OPERABLE CEA 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months See ITS position indicator channels indicate within 3.1.15 5 inches of each other.

SR 3.1.5.3 SR 3.1.5.3 Verify full length CEA freedom of movement 92 days (trippability) by moving each individual LA01 full length CEA that is not fully inserted In accordance with the in the core at least 5 inches. Surveillance Frequency SR 3.1.5.4 Not used.

Control Program SR 3.1.5.4* Perform a CHANNEL FUNCTIONAL TEST of each 24 months See ITS 3.1.15 reed switch position transmitter channel.

SR 3.1.5.5 SR 3.1.5.5 Verify each full length CEA drop time and Prior to the the arithmetic average of all full length first reactor CEA drop times is within at least one of criticality, the limit sets: after each removal of the Set Average (sec) Individual (sec) reactor head I # 3.0 # 3.2 II # 3.2 # 3.4 III # 3.4 # 3.6 SR 3.1.5.6 For each CEA drop time measurement Prior to performed under SR 3.1.5.5, verify that the reactor L01 appropriate CPC and COLSS addressable criticality constant adjustments have been made.

This SR is not applicable until return to Mode 2 from the Unit 3 Cycle 9 refueling outage with addition commitments made in Edison letter dated See ITS 3.1.15 February 6, 1997. The safety justification for not complying with this SR is included in the February 6, 1997 letter.

SAN ONOFRE--UNIT 3 3.1-11 Amendment No. 116, 126 Attachment 1, Volume 4, Rev. 0, Page 86 of 345

Attachment 1, Volume 4, Rev. 0, Page 87 of 345 DISCUSSION OF CHANGES ITS 3.1.5, CONTROL ELEMENT ASSEMBLY (CEA) ALIGNMENT ADMINISTRATIVE CHANGES A01 In the conversion of the San Onofre Nuclear Generating Station (SONGS)

Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1432, Rev. 3.0, "Standard Technical Specifications Combustion Engineering Plants" (ISTS) and additional approved Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.1.5 contains the requirements for control element assembly (CEA) alignment. The CTS LCO requires all full length CEAs to be OPERABLE and all full length and part length CEAs to be aligned within 7 inches of all other CEAs in its group. The various CTS ACTIONS are for the conditions when the CEAs are trippable and misaligned by certain amounts and when CEAs are untrippable.

The ITS reorganizes the LCO statement into two parts: one that requires all full length CEAs to be OPERABLE, and one that requires the full and part length CEAs to be aligned within 7 inches (indicated position) of their respective groups.

Furthermore, CTS 3.1.5 Condition D (second Condition) uses the term "untrippable." ITS 3.1.5 Condition D uses the term "inoperable," since as stated above and in the Bases, OPERABLE means trippable. Therefore, the more common term utilized in the Technical Specifications, "inoperable" is being used.

Furthermore, CTS 3.1.5 Conditions A, B, and D (third Condition) specifies that the CEAs are "trippable and misaligned" or "trippable but misaligned." ITS 3.1.5 Conditions A, B, and D (third Condition) do not use the "trippable" term; only the "misaligned" term is used. This changes the CTS by separating OPERABILITY and misalignment in the LCO statement, and editorially rewording the LCO to clarify that the 7 inch limit is indicated position. It further clarifies that untrippable means inoperable.

This change corrects an ambiguity regarding CEAs that are inoperable versus out of alignment. The LCO statement is more clearly worded to ensure the concept of OPERABILITY and out of alignment/misaligned are two different aspects of the CEA requirements. A CEA is OPERABLE if it can be tripped into the core. This is consistent with the Bases, of which the first statement of the Background equates OPERABILITY with trippability. The LCO statement is revised to clarify the alignment limit is separate from the OPERABILITY of the CEA; a CEA can remain OPERABLE even though it may be beyond the alignment limit. The term "trippable" as currently used in CTS 3.1.5 Conditions A, B, and D (third Condition) is redundant, since there are separate ACTIONS for when the CEA is not trippable (i.e., inoperable) and when the CEAs are misaligned. Since the LCO statement clearly separates the two attributes of CEAs, there is no reason to include the term "trippable" in these Conditions.

Furthermore, the previous wording of "trippable" was ambiguous for CEAs that, for instance, had slow drop times but were still trippable. These slow CEAs are inoperable (i.e., cannot provide the required SDM in the required time), and the revised ACTION and terminology properly addresses this condition. This change San Onofre Unit 2 and 3 Page 1 of 7 Attachment 1, Volume 4, Rev. 0, Page 87 of 345

Attachment 1, Volume 4, Rev. 0, Page 88 of 345 DISCUSSION OF CHANGES ITS 3.1.5, CONTROL ELEMENT ASSEMBLY (CEA) ALIGNMENT is a clarification that does not affect the application of the TS and as such is administrative.

A03 CTS 3.1.5 Required Actions A.1, B.1, and C.1 state to initiate THERMAL POWER reduction in accordance with COLR requirements when CEAs are misaligned. ITS 3.1.5 Required Actions A.1, B.1, and C.1 state to initiate action to reduce THERMAL POWER in accordance with COLR requirements. This changes the CTS by editorially re-wording the Required Actions to be consistent with the ISTS manner in stating these types of Required Actions.

The ISTS uses the term "initiate action to" for these types of Required Actions.

Therefore, this change is consistent with this ISTS terminology and is acceptable since the Required Actions are not being changed. This change is designated as administrative since it does not result in any technical changes to the CTS.

A04 CTS 3.1.5 Condition D, third and fourth Conditions, uses the phrase "more than one" when referring to the number of full length and part length CEAs that are misaligned. The Conditions also use the phrase "misaligned from any other CEA in its group." ITS 3.1.5 Condition D, third and fourth Conditions, uses the phrase "two or more" when referring to the number of full length and part length CEAs that are misaligned and do not include the redundant words "any other CEA in."

This changes the CTS by clearly stating the minimum number of CEAs the Condition applies to and deleting the redundant words about "any other CEA" in its group.

The change is acceptable since the actual number has not changed. The Conditions are only being clarified to actually state the minimum number of CEAs that result in entry into these Conditions, in lieu of the phrase "more than one."

Since "more than one" is the same as "two or more," this change is only editorial in nature to be consistent with the terminology used in similar type of Conditions in the ISTS. Furthermore, the words "any other CEA" are redundant since the Condition already states it is misaligned from its group. In addition, the deletion of the wording is consistent with similar wording in CTS 3.1.5 Conditions A, B, and C. This change is designated as administrative since it does not result in any technical changes to the CTS.

A05 CTS SR 3.1.5.1 requires verification that the position of each CEA is within 7 inches of all other CEAs in its group. ITS SR 3.1.5.1 requires the "indicated" positionto be verified. The changes the CTS by clarifying that the position to be verified is the "indicated" position.

This proposed change clarifies that the "indicated" position is the CEA position to be verified to be within 7 inches of all other CEAs in the group. The position of the CEAs is via indication from the reed switch position transmitters and the pulse counter, as described in the Bases for the CTS and ITS SR. Adding clarification to the TS by adding the word "indicated" is acceptable and is an administrative change, since this is the normal manner in which the position is verified.

San Onofre Unit 2 and 3 Page 2 of 7 Attachment 1, Volume 4, Rev. 0, Page 88 of 345

Attachment 1, Volume 4, Rev. 0, Page 89 of 345 DISCUSSION OF CHANGES ITS 3.1.5, CONTROL ELEMENT ASSEMBLY (CEA) ALIGNMENT MORE RESTRICTIVE CHANGES M01 CTS 3.1.5 ACTION D provides the actions when one full length CEA is untrippable (i.e., inoperable). However, no ACTIONS are provided when two or more full length CEAs are inoperable. Thus, CTS LCO 3.0.3 must be entered, which requires initiation of action within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to be in MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months .

ITS 3.1.5 ACTION D provides the actions for when one "or more" full length CEAs are inoperable. This changes the CTS by providing a specific action for when two or more CEAs are inoperable, in lieu of requiring an LCO 3.0.3 entry.

The change from the term "untrippable" to "inoperable" is discussed in DOC A02.

The purpose of CTS LCO 3.0.3, for this specific condition, is to place the unit in a MODE in which CTS 3.1.5 does not apply. ITS 3.1.5 ACTION D provides the same results, in that ITS 3.1.5 Required Action D.1 requires placing the unit in MODE 3, which will exit the Applicability of LCO 3.1.5. The time to reach MODE 3 has been reduced from 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months in LCO 3.0.3 to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months in ITS 3.1.5 Required Action D.1. Therefore, since the end result, being in MODE 3, is the same in the CTS and ITS, this change is acceptable. This change is more restrictive since the total time to reach MODE 3 has been reduced from 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 4 - Removal of LCO, SR, or other TS requirement to the LCS, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS SR 3.1.5.1 requires verification that the position of each full and part length CEA is within 7 inches of all other CEA in its group every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . CTS SR 3.1.5.3 requires verification that full length CEA freedom of movement (trippability) by moving each individual full length CEA that is not fully inserted in the core at least 5 inches every 92 days. ITS SR 3.1.5.1 and SR 3.1.5.3 require similar Surveillances but specify the periodic Frequency as "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequencies for the SR to the Surveillance Frequency Control Program.

The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. In addition:

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program; San Onofre Unit 2 and 3 Page 3 of 7 Attachment 1, Volume 4, Rev. 0, Page 89 of 345

Attachment 1, Volume 4, Rev. 0, Page 90 of 345 DISCUSSION OF CHANGES ITS 3.1.5, CONTROL ELEMENT ASSEMBLY (CEA) ALIGNMENT

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1; and

c. The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

The referenced document, NEI 04-10, Rev. 1, provides a detailed description of the process to be followed when considering changes to a Surveillance Frequency. NEI 04-10, Rev. 1, has been reviewed and approved by the NRC.

Therefore, the process will not be discussed further here.

The relocation of the specified Surveillance Frequency to licensee control is consistent with Regulatory Guides 1.174 and 1.177. Regulatory Guide 1.177 provides guidance for changing Surveillance Frequencies and Completion Times.

However, for allowable risk changes associated with Surveillance Frequency extensions, it refers to Regulatory Guide 1.174, which provides quantitative risk acceptance guidelines for changes to core damage frequency (CDF) and large early release frequency (LERF). Regulatory Guide 1.174 provides additional guidelines that have been adapted in the risk-informed methodology for controlling changes to Surveillance Frequencies.

Regulatory Guide 1.174 identifies five key safety principles to be met for all risk-informed applications and to be explicitly addressed in risk-informed plant program change applications.

1. The proposed change meets the current regulations unless it is explicitly related to a requested exemption or rule change.

10 CFR 50.36(c) provides that TS will include items in the following categories:

"(3) Surveillance requirements. Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met."

This change proposes to relocate various Frequencies for the performance of the Surveillance Requirements to a licensee-controlled program using an NRC approved methodology for control of the Surveillance Frequencies. The Surveillance Requirements themselves will remain in TS. This is consistent with other NRC approved TS changes in which the Surveillance Frequencies are not under NRC control, such as Surveillances that are performed in accordance with the Inservice Testing Program or the Containment Leakage Rate Testing Program, where the Frequencies vary based on the past performance of the subject components. Thus, this proposed change meets criterion 1 above.

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Attachment 1, Volume 4, Rev. 0, Page 91 of 345 DISCUSSION OF CHANGES ITS 3.1.5, CONTROL ELEMENT ASSEMBLY (CEA) ALIGNMENT

2. The proposed change is consistent with the defense-in-depth philosophy.

As described in Position 2.2.1.1 of Regulatory Guide 1.174, consistency with the defense-in-depth philosophy is maintained if:

A reasonable balance is preserved among prevention of core damage, prevention of containment failure, and consequence mitigation; Over-reliance on programmatic activities to compensate for weaknesses in plant design is avoided; System redundancy, independence, and diversity are preserved commensurate with the expected frequency, consequences of challenges to the system, and uncertainties (e.g., no risk outliers);

Defenses against potential common cause failures are preserved, and the potential for the introduction of new common cause failure mechanisms is assessed; Independence of barriers is not degraded; Defenses against human errors are preserved; and The intent of the General Design Criteria in 10 CFR Part 50, Appendix A is maintained.

These defense-in-depth objectives apply to all risk-informed applications, and for some of the issues involved (e.g., no over-reliance on programmatic activities and defense against human errors), it is fairly straightforward to apply them to this proposed change. The use of the multiple risk metrics of CDF and LERF and controlling the change resulting from the implementation of this initiative would maintain a balance between prevention of core damage, prevention of containment failure, and consequence mitigation.

Redundancy, diversity, and independence of safety systems are considered as part of the risk categorization to ensure that these qualities are not adversely affected. Independence of barriers and defense against common cause failures are also considered in the categorization. The improved understanding of the relative importance of plant components to risk resulting from the development of this program promotes an improved overall understanding of how the SSCs contribute to the plant's defense-in-depth.

3. The proposed change maintains sufficient safety margins.

Conformance with this principle is assured since SSC design, operation, testing methods and acceptance criteria specified in the Codes and Standards or alternatives approved for use by the NRC, will continue to be met as described in the plant licensing basis (e.g., UFSAR, or Technical Specifications Bases). Also, the safety analysis acceptance criteria in the San Onofre Unit 2 and 3 Page 5 of 7 Attachment 1, Volume 4, Rev. 0, Page 91 of 345

Attachment 1, Volume 4, Rev. 0, Page 92 of 345 DISCUSSION OF CHANGES ITS 3.1.5, CONTROL ELEMENT ASSEMBLY (CEA) ALIGNMENT licensing basis (e.g., UFSAR, supporting analyses, etc.) are met with the proposed change.

4. When proposed changes result in an increase in core damage frequency or risk, the increases should be small and consistent with the intent of the Commission's Safety Goal Policy Statement.

NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies,"

will require that changes in core damage frequency or risk are small and consistent with the intent of the Commission's Safety Goal Policy.

5. The impact of the proposed change should be monitored using performance measurement strategies.

NEI 04-10 will require that changes in Surveillance Frequencies be monitored using performance management strategies.

Therefore, the proposed change is consistent with the guidance in Regulatory Guide 1.174.

This change is designated as a less restrictive removal of detail change because Surveillance Frequencies are being removed from the Technical Specifications.

LA02 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.1.5 Required Actions A.2.1, B.2 and C.2.1 (for regulating, shutdown and part length CEAs, respectively) require, when one CEA is misaligned from its group, restoration of the misaligned CEA to within 7 inches of its group or as required by CTS 3.1.5 Required Actions A.2.2 and C.2.2, to align the remainder of the CEAs in the group to within 7 inches of the misaligned CEA while maintaining the insertion limit of LCO 3.1.7. ITS 3.1.5 Required Actions A.2, B.2, and C.2 require restoration of CEA alignment for the same Condition. This changes the CTS by moving the details (i.e., aligning the CEA to within 7 inches of its group or aligning the group to within 7 inches of the misaligned CEA) from the Required Actions to the Bases.

CTS 3.1.5 Required Actions A.2.1, A.2.2, B.2, C.2.1, and C.2.2 contain detail on how to restore CEA alignment. This level of detail is not required in the Technical Specifications. This information is already contained in the Bases which state that within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months the misaligned CEA(s) must be restored to within 7 inches of its group or the misaligned CEA's group must be aligned to within 7 inches of the misaligned CEA. The Bases will clarify that aligning a shutdown CEA's group to within 7 inches of the misaligned CEA is not permitted. The Required Actions and Completion Times are not changed, as CEA alignment must still be restored within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This change is acceptable because this type of procedural detail will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specifications Bases Control Program in Chapter 5. This change is designated as a less restrictive removal of detail change because procedural details for restoring CEA alignment are being removed from the Technical Specifications.

San Onofre Unit 2 and 3 Page 6 of 7 Attachment 1, Volume 4, Rev. 0, Page 92 of 345

Attachment 1, Volume 4, Rev. 0, Page 93 of 345 DISCUSSION OF CHANGES ITS 3.1.5, CONTROL ELEMENT ASSEMBLY (CEA) ALIGNMENT LESS RESTRICTIVE CHANGES L01 (Category 5 - Deletion of Surveillance Requirement) CTS SR 3.1.5.6 requires verification that the appropriate CPC and COLSS addressable constant adjustments have been made whenever CEA drop time testing is performed.

The ITS will not contain this SR. This changes the CTS by deleting a Surveillance Requirement that requires verification the appropriate adjustments of the CPC and COLSS addressable constants have been made whenever CEA drop time testing is performed.

The purpose of SR 3.1.5.6 is to verify appropriate adjustments have been made to the CPC and COLSS addressable constants for each CEA drop time measurement performed. This proposed change deletes an SR that contains detailed information that is more appropriate for plant procedures than for an SR.

This change proposes to relocate the information in the SR to the appropriate plant procedures. COLSS and CPC addressable constants are adjusted and/or verified throughout the startup process via plant procedures. The drop time adjustments for the appropriate addressable constants are included in these procedures. The TS do not currently specifically require adjustment or verification of adjustment of all CPC and COLSS addressable constants. This information will be appropriately controlled in plant procedures as requirements for control, verification, and adjustments of other CPC and COLSS addressable constants are currently controlled. The deletion of this SR from TS is acceptable, because it is more appropriate to be under utility control. Also the CEA drop times are required to be tested per ITS SR 3.1.5.5, which ensures the CEA drop times are within limits. This change is designated as a less restrictive because a Surveillance Requirement is being deleted from Technical Specifications.

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Attachment 1, Volume 4, Rev. 0, Page 94 of 345 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 4, Rev. 0, Page 94 of 345

Attachment 1, Volume 4, Rev. 0, Page 95 of 345 CEA Alignment (Digital) 2 U2/U3 CTS 3.1.4 5

5 3.1 REACTIVITY CONTROL SYSTEMS 5 2 3.1.4 Control Element Assembly (CEA) Alignment (Digital) 5 5

LCO 3.1.5 LCO 3.1.4 All full length CEAs shall be OPERABLE.

5 AND 3

All full and part length CEAs shall be aligned to within [7 inches]

(indicated position) of their respective groups.

Applicability APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME regulating Initiate action to 6

ACTION A A. One or more CEAs A.1 Reduce THERMAL 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months misaligned from its POWER in accordance with 15 minutes group by > [7 inches] Figure 3.1.4-1. 1 and [19 inches]. the COLR AND OR A.2 Restore CEA Alignment. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months One CEA misaligned from its group by

> [19 inches]. INSERT 1 6 ACTION D 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 6 D associated Completion D

Time not met.

of Condition A, B, or C OR One or more full length CEAs inoperable.

from its group OR full length OR Two or more CEAs 7 misaligned by Two or more part length CEAs misaligned from its group by >

> [19 inches]. 7 inches.

CEOG STS 3.1.4-1 Rev. 3.0, 03/31/04 1 5 San Onofre - Draft Amendment XXX 5

Attachment 1, Volume 4, Rev. 0, Page 95 of 345

Attachment 1, Volume 4, Rev. 0, Page 96 of 345 U2/U3 CTS 3.1.5 6 INSERT 1 ACTION B B. One shutdown CEA B.1 Initiate action to reduce 15 minutes misaligned from its THERMAL POWER in group by > 7 inches. accordance with the COLR.

AND B.2 Restore CEA alignment. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ACTION C C. One part length CEA C.1 Initiate action to reduce 15 minutes misaligned from its THERMAL POWER in group by > 7 inches. accordance with the COLR.

AND C.2 Restore CEA alignment. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Insert Page 3.1.5-1 Attachment 1, Volume 4, Rev. 0, Page 96 of 345

Attachment 1, Volume 4, Rev. 0, Page 97 of 345 CEA Alignment (Digital) 2 U2/U3 CTS 3.1.4 5 5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 5

SR 3.1.5.1 SR 3.1.4.1 Verify the indicated position of each full and part 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 5 length CEA is within [7 inches] of all other CEAs in 3 its group.

5 SR 3.1.4.2 Verify that, for each CEA, its OPERABLE CEA 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 7

5 position indicator channels indicate within [5 inches]

Not used. of each other.

SR 3.1.5.3 5 SR 3.1.4.3 Verify full length CEA freedom of movement 92 days 5 (trippability) by moving each individual full length 3 CEA that is not fully inserted in the core at least

[5 inches].

5 5

SR 3.1.4.4 Perform a CHANNEL FUNCTIONAL TEST of each [18] months 7 Not used.

reed switch position transmitter channel.

SR 3.1.5.5 5 SR 3.1.4.5 Verify each full length CEA drop time Prior to reactor 5 [3.5] seconds and the arithmetic average of all full criticality, after length CEA drop times [3.2] seconds. each removal of 1 INSERT 2 the reactor head In accordance with the TSTF-Surveillance Frequency 425-A Control Program CEOG STS 3.1.4-2 Rev. 3.0, 03/31/04 1 5 San Onofre - Draft Amendment XXX 5

Attachment 1, Volume 4, Rev. 0, Page 97 of 345

Attachment 1, Volume 4, Rev. 0, Page 98 of 345 3.1.5 1 INSERT 2 is within at least one of the limit sets:

Set Average (sec) Individual (sec)

I < 3.0 < 3.2 II < 3.2 < 3.4 III < 3.4 < 3.6 Insert Page 3.1-5-2 Attachment 1, Volume 4, Rev. 0, Page 98 of 345

Attachment 1, Volume 4, Rev. 0, Page 99 of 345 CEA Alignment (Digital) 2 U2/U3 CTS 3.1.4 5 5

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

When core power is reduced to 60% RTP per this limit curve, further reduction is not required by this Specification. 4

[ NOT TO BE USED FOR OPERATION.

FOR ILLUSTRATION PURPOSES ONLY. ]

Figure 3.1.4-1 (page 1 of 1)

Required Power Reduction After CEA Deviation CEOG STS 3.1.4-3 Rev. 3.0, 03/31/04 1 5 San Onofre - Draft Amendment XXX 5

Attachment 1, Volume 4, Rev. 0, Page 99 of 345

Attachment 1, Volume 4, Rev. 0, Page 100 of 345 JUSTIFICATION FOR DEVIATIONS ITS 3.1.5, CONTROL ELEMENT ASSEMBLY (CEA) ALIGNMENT

1. Changes are made (additions, deletions, and/or changes) to the ISTS which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The headings for ISTS 3.1.4 (ITS 3.1.5) include the parenthetical expression

"(Digital)." This identifying information is not included in the San Onofre Nuclear Generating Station (SONGS) ITS. This information is provided in the NUREG to assist in identifying the appropriate Specification to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific ITS implementation. SONGS Units 2 and 3 are digital plants; therefore analog requirements and specific labels that identify a requirement is digital are not required.

3. The ISTS contains bracketed information and/or values that are generic to all Combustion Engineering vintage plants. The brackets are removed and the proper plant specific information/value is provided. This is acceptable since the information/value is revised to reflect the current licensing basis.

4. The ISTS contains a place keeper for the power reduction curve associated with the Actions for misaligned CEAs. San Onofre has previously relocated this Table to the COLR. Therefore, this Table is being deleted from the SONGS specific ITS.

5. The Specification/SR number has been changed to be consistent with the Specification number in the SONGS CTS. SONGS CTS contained two SDM Specifications (CTS 3.1.1, SDM in MODES 3 and 4, and CTS 3.1.2, SDM in MODE 5) which are being combined into one Specification (ITS 3.1.1), consistent with NUREG-1432. SCE has decided not to renumber the CTS to be consistent with the ISTS because by doing so would result in the unnecessary administrative burden of changing TS numbers in plant procedures.

6. ISTS 3.1.4 (ITS 3.1.5) ACTIONS have been modified to be consistent with the SONGS safety analysis with respect to the number of CEAs that can be misaligned and the amount of misalignment allowed. The SONGS safety analysis only allows one full length and one part length CEA to be misaligned by more than 7 inches.

Specifically, one full length (either a regulating or a shutdown) CEA and one part length CEA can be misaligned. Therefore, ACTIONS A, B, and C cover these allowed conditions. If more than one (i.e., two or more) full length or more than one (i.e., two or more) part length CEA is misaligned by more than 7 inches, this condition is outside the accident analysis assumptions; thus a unit shutdown is required (ACTION D). Furthermore, the CTS ACTIONS require initiation of action to reduce THERMAL POWER in accordance with the COLR within 15 minutes in lieu of the ITS allowance to allow up to one hour to complete the power reduction. The COLR requirements assume power reduction starts within 15 minutes. These proposed ACTIONS are consistent with the CTS requirements (as modified by editorial changes to be consistent with ITS terminology and format).

7. ISTS SRs 3.1.4.2 and 3.1.4.4 have been moved from this Specification to a new ITS 3.1.15 (as SR 3.1.15.1 and SR 3.1.15.2). For the justification, see the JFDs for ITS 3.1.15. The SR numbers of the remaining SRs in this Specification have not been changed due to the deletion of these two SRs. SCE has decided not to renumber the CTS SRs because by doing so would result in the unnecessary San Onofre Unit 2 and 3 Page 1 of 2 Attachment 1, Volume 4, Rev. 0, Page 100 of 345

Attachment 1, Volume 4, Rev. 0, Page 101 of 345 JUSTIFICATION FOR DEVIATIONS ITS 3.1.5, CONTROL ELEMENT ASSEMBLY (CEA) ALIGNMENT administrative burden of changing TS numbers in plant procedures. For this reason, "Not used" SR numbers are also maintained in the ITS.

San Onofre Unit 2 and 3 Page 2 of 2 Attachment 1, Volume 4, Rev. 0, Page 101 of 345

Attachment 1, Volume 4, Rev. 0, Page 102 of 345 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

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CEA Alignment (Digital)

B 3.1.4 5 5

B 3.1 REACTIVITY CONTROL SYSTEMS B 3.1.4 Control Element Assembly (CEA) Alignment (Digital) 5 2 5

BASES BACKGROUND The OPERABILITY (i.e., trippability) of the shutdown and regulating Control Element Assemblies (CEAs) is an initial assumption in all safety analyses that assume CEA insertion upon reactor trip. Maximum CEA misalignment is an initial assumption in the safety analyses that directly affects core power distributions and assumptions of available SDM.

The applicable criteria for these reactivity and power distribution design requirements are 10 CFR 50, Appendix A, GDC 10 and GDC 26 (Ref. 1) and 10 CFR 50.46, "Acceptance Criteria for Emergency Core Cooling Systems for Light Water Cooled Nuclear Power Plants" (Ref. 2).

Mechanical or electrical failures may cause a CEA to become inoperable or to become misaligned from its group. CEA inoperability or misalignment may cause increased power peaking, due to the asymmetric reactivity distribution and a reduction in the total available CEA worth for reactor shutdown. Therefore, CEA alignment and operability are related to core operation in design power peaking limits and the core design requirement of a minimum SDM.

Limits on CEA alignment and OPERABILITY have been established, and all CEA positions are monitored and controlled during power operation to ensure that the power distribution and reactivity limits defined by the design power peaking and SDM limits are preserved.

CEAs are moved by their control element drive mechanisms (CEDMs).

Each CEDM moves its CEA one step (approximately 3/4 inch) at a time, but at varying rates (steps per minute) depending on the signal output from the Control Element Drive Mechanism Control System (CEDMCS).

The CEAs are arranged into groups that are radially symmetric.

Therefore, movement of the CEAs does not introduce radial asymmetries in the core power distribution. The shutdown and regulating CEAs provide the required reactivity worth for immediate reactor shutdown upon a reactor trip. The regulating CEAs also provide reactivity (power level) control during normal operation and transients. Their movement may be 1 automatically controlled by the Reactor Regulating System. Part length CEAs are not credited in the safety analyses for shutting down the reactor, as are the regulating and shutdown groups. The part length CEAs are used solely for ASI control. 1 and reactivity (power level) control during normal operation and transients CEOG STS B 3.1.4-1 Rev. 3.0, 03/31/04 1 5 San Onofre - Draft Revision XXX 5

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CEA Alignment (Digital)

B 3.1.4 5 5

BASES BACKGROUND (continued)

The axial position of shutdown and regulating CEAs is indicated by two separate and independent systems, which are the Plant Computer CEA Position Indication System and the Reed Switch Position Indication System.

The Plant Computer CEA Position Indication System counts the commands sent to the CEA gripper coils from the CEDMCS that moves the CEAs. There is one step counter for each group of CEAs. Individual CEAs in a group all receive the same signal to move and should, 1 therefore, all be at the same position indicated by the group step counter for that group. The Plant Computer CEA Position Indication System is considered highly precise (+/- one step or +/- 3/4 inch). If a CEA does not move one step for each command signal, the step counter will still count the command and incorrectly reflect the position of the CEA.

The Reed Switch Position Indication System provides a highly accurate indication of actual CEA position, but at a lower precision than the step counters. This system is based on inductive analog signals from a series of reed switches spaced along a tube with a center to center distance of 1.5 inches, which is two steps. To increase the reliability of the system, there are redundant reed switches at each position.

APPLICABLE CEA misalignment accidents are analyzed in the safety analysis (Ref. 3).

SAFETY The accident analysis defines CEA misoperation as any event, with the ANALYSES exception of sequential group withdrawals, which could result from a single malfunction in the reactivity control systems. For example, CEA misalignment may be caused by a malfunction of the CEDM, CEDMCS, or by operator error. A stuck CEA may be caused by mechanical a malfunction of the CEDMCS or jamming of the CEA fingers or of the gripper. Inadvertent withdrawal of a by operator error. single CEA may be caused by opening of the electrical circuit of the 7 CEDM holding coil for a full length or part length CEA. A dropped CEA subgroup could be caused by an electrical failure in the CEA coil power programmers.

The acceptance criteria for addressing CEA inoperability or misalignment are that:

a. There shall be no violations of either:

1. Specified acceptable fuel design limits or

2. Reactor Coolant System (RCS) pressure boundary integrity and

b. The core must remain subcritical after accident transients.

CEOG STS B 3.1.4-2 Rev. 3.0, 03/31/04 1 5 San Onofre - Draft Revision XXX 5

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CEA Alignment (Digital)

B 3.1.4 5 5

BASES APPLICABLE SAFETY ANALYSES (continued)

Three types of misalignment are distinguished. During movement of a group, one CEA may stop moving while the other CEAs in the group continue. This condition may cause excessive power peaking. The second type of misalignment occurs if one CEA fails to insert upon a reactor trip and remains stuck fully withdrawn. This condition requires an evaluation to determine that sufficient reactivity worth is held in the remaining CEAs to meet the SDM requirement with the maximum worth CEA stuck fully withdrawn. If a CEA is stuck in the fully withdrawn position, its worth is added to the SDM requirement, since the safety analysis does not take two stuck CEAs into account. The third type of misalignment occurs when one CEA drops partially or fully into the reactor core. This event causes an initial power reduction followed by a return towards the original power due to positive reactivity feedback from the negative moderator temperature coefficient. Increased peaking during the power increase may result in excessive local linear heat rates (LHRs).

Two types of analyses are performed in regard to static CEA misalignment (Ref. 4). With CEA banks at their insertion limits, one type 0 3 withdrawn of analysis considers the case when any one CEA is inserted [ ] inches 1

into the core. The second type of analysis considers the case of a single 5 CEA withdrawn [ ] inches from a bank inserted to its insertion limit. 3 Satisfying limits on departure from nucleate boiling ratio (DNBR) in both of these cases bounds the situation when a CEA is misaligned from its 5

group by [7 inches]. The CPC CEA withdrawal prohibit limits CEA misalignment to 5 inches. 3 1 Another type of misalignment occurs if one CEA fails to insert upon a reactor trip and remains stuck fully withdrawn. This condition is assumed 1 in the evaluation to determine that the required SDM is met with the maximum worth CEA also fully withdrawn (Ref. 5).

The effect of any misoperated CEA on the core power distribution will be assessed by the CEA calculators, and an appropriately augmented power distribution penalty factor will be supplied as input to the core protection calculators (CPCs). As the reactor core responds to the reactivity changes caused by the misoperated CEA and the ensuing reactor coolant and Doppler feedback effects, the CPCs will initiate a low DNBR or high local power density trip signal if specified acceptable fuel design limits (SAFDLs) are approached.

CEOG STS B 3.1.4-3 Rev. 3.0, 03/31/04 1 5 San Onofre - Draft Revision XXX 5

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CEA Alignment (Digital)

B 3.1.4 5 5

BASES APPLICABLE SAFETY ANALYSES (continued)

Since the CEA drop incidents result in the most rapid approach to SAFDLs caused by a CEA misoperation, the accident analysis analyzed a single full length CEA drop, a single part length CEA drop, and a part length CEA subgroup drop. The most rapid approach to the DNBR SAFDL may be caused by either a single full length drop or a part length CEA subgroup drop depending upon initial conditions. The most rapid approach to the fuel centerline melt SAFDL is caused by a single part length CEA drop.

In the case of the full length CEA drop, a prompt decrease in core average power and a distortion in radial power are initially produced, which when conservatively coupled result in local power and heat flux increases, and a decrease in DNBR. For plant operation within the DNBR and local power density (LPD) LCOs, DNBR and LPD trips can normally be avoided on a dropped CEA.

For a part length CEA subgroup drop, a distortion in power distribution, and a decrease in core power are produced. As the dropped part length CEA subgroup is detected, an appropriate power distribution penalty factor is supplied to the CPCs, and a reactor trip signal on low DNBR is generated. For the part length CEA drop, both core average power and three dimensional peak to average power density increase promptly. As the dropped part length CEA is detected, core power and an appropriately augmented power distribution penalty factor are supplied to the CPCs.

CEA alignment limits and OPERABILITY requirements satisfy Criteria 2 and 3 of 10 CFR 50.36(c)(2)(ii).

LCO The limits on shutdown and regulating CEA alignments ensure that the assumptions in the safety analysis will remain valid. The requirements on CEA OPERABILITY ensure that upon reactor trip, the CEAs will be available and will be inserted to provide enough negative reactivity to shut down the reactor. The CEA OPERABILITY requirements (i.e., trippability) are separate from the alignment requirements which ensure that the CEA banks maintain the correct power distribution and CEA alignment. The CEA OPERABILITY requirement is satisfied provided the CEA will fully insert in the required CEA drop time assumed in the safety analysis. CEA control malfunctions that result in the inability to move a CEA (e.g., CEA lift coil failures), but that do not impact trippability, do not result in CEA inoperability.

CEOG STS B 3.1.4-4 Rev. 3.0, 03/31/04 1 5 San Onofre - Draft Revision XXX 5

Attachment 1, Volume 4, Rev. 0, Page 106 of 345

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CEA Alignment (Digital)

B 3.1.4 5 5

BASES LCO (continued)

The requirement is to maintain the CEA alignment to within [7 inches] 3 between any CEA and its group. The minimum misalignment assumed in safety analysis is [19 inches], and in some cases, a total misalignment 1 from fully withdrawn to fully inserted is assumed.

Failure to meet the requirements of this LCO may produce unacceptable power peaking factors and LHRs, or unacceptable SDMs, all of which may constitute initial conditions inconsistent with the safety analysis.

APPLICABILITY The requirements on CEA OPERABILITY and alignment are applicable in MODES 1 and 2 because these are the only MODES in which neutron (or fission) power is generated, and the OPERABILITY (i.e., trippability) and alignment of CEAs have the potential to affect the safety of the plant. In MODES 3, 4, 5, and 6, the alignment limits do not apply because the CEAs are bottomed, and the reactor is shut down and not producing fission power. In the shutdown modes, the OPERABILITY of the shutdown and regulating CEAs has the potential to affect the required SDM, but this effect can be compensated for by an increase in the boron concentration of the RCS. See LCO 3.1.1, "SHUTDOWN MARGIN (SDM)," for SDM in MODES 3, 4, and 5, and LCO 3.9.1, "Boron Concentration," for boron concentration requirements during refueling.

, B.1, and B.2 ACTIONS A.1 and A.2 is

, regulating or shutdown If one or more CEAs (regulating, shutdown or part length) are misaligned by [7 inches] and [19 inches], or one CEA misaligned by > [19 inches],

15 minutes a > continued operation in MODES 1 and 2 may continue, provided, within 10 power reduction is 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , the power is reduced in accordance with Figure 3.1.4-1, and initiated within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months CEA alignment is restored. the COLR the misaligned CEA is aligned within 7 inches of its group or, Regulating and part length CEA alignment can be restored by either for a regulating CEA only, the aligning the misaligned CEA(s) to within [7 inches] of its group or aligning misaligned CEA's group is aligned within 7 inches of the the misaligned CEA's group to within [7 inches] of the misaligned CEA. 9 misaligned CEA (provided the Shutdown CEA alignment can be restored by aligning the misaligned requirements of LCO 3.1.7, CEA(s) to within [7 inches] of its group.

"Regulating Control Assembly (CEA) Insertion Limits," can be reduction maintained). Xenon redistribution in the core starts to occur as soon as a CEA becomes misaligned. Reducing THERMAL POWER in accordance with Initiating a Figure 3.1.4-1 (in the accompanying LCO) ensures acceptable power 1 the COLR distributions are maintained (Ref. 6). For small misalignments

(< [19 inches]) of the CEAs, there is: 3

<7 CEOG STS B 3.1.4-5 Rev. 3.0, 03/31/04 1 5 San Onofre - Draft Revision XXX 5

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CEA Alignment (Digital)

B 3.1.4 5 5

BASES ACTIONS (continued)

a. A small effect on the time dependent long term power distributions relative to those used in generating LCOs and limiting safety system settings (LSSS) setpoints,

b. A negligible effect on the available SDM, and

c. A small effect on the ejected CEA worth used in the accident analysis. >7 3

With a large CEA misalignment ( [19 inches]), however, this misalignment would cause distortion of the core power distribution. This distortion may, in turn, have a significant effect on the time dependent, long term power distributions relative to those used in generating LCOs and LSSS setpoints. The effect on the available SDM and the ejected CEA worth used in the accident analysis remain small. Therefore, this condition is limited to the single CEA misalignment, while still allowing 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for recovery. In both cases, a 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months time period is sufficient to:

a. Identify cause of a misaligned CEA,

b. Take appropriate corrective action to realign the CEAs, and

c. Minimize the effects of xenon redistribution.

The CEA must be returned to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or transition to MODE 3.

9 INSERT 1 D

B.1 , B, or C If a Required Action or associated Completion Time of Condition A is not met, one or more full length CEAs are inoperable, or two or more CEAs are misaligned by > [19 inches], the unit is required to be brought to than one full MODE 3. By being brought to MODE 3, the unit is brought outside its length or part length MODE of applicability. This is because these cases are indicative of a loss of SDM and power distribution, and a loss of safety function, 9 respectively.

When a Required Action cannot be completed within the required Completion Time, a controlled shutdown should be commenced. The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, for reaching MODE 3 from full power conditions in an orderly manner and without challenging plant systems.

CEOG STS B 3.1.4-6 Rev. 3.0, 03/31/04 1 5 San Onofre - Draft Revision XXX 5

Attachment 1, Volume 4, Rev. 0, Page 108 of 345

Attachment 1, Volume 4, Rev. 0, Page 109 of 345 B 3.1.5 9 INSERT 1 C.1 and C.2 Although a part length CEA has less of an effect on core flux than a full length CEA, a misaligned part length CEA will still result in xenon redistribution and affect core power distribution. Therefore, within 15 minutes a power reduction must be initiated in accordance with the COLR requirements, and within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months the misaligned CEA is aligned within 7 inches of its group or the misaligned CEA's group is aligned within 7 inches of the misaligned CEA (provided the requirements of LCO 3.1.8, "Part Length Regulating Control Element Assembly (CEA) Insertion Limits," can be maintained). Initiating a power reduction within 15 minutes and requiring realignment within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months minimizes these effects and ensures acceptable power distribution is maintained.

Insert Page B 3.1.5-6 Attachment 1, Volume 4, Rev. 0, Page 109 of 345

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CEA Alignment (Digital)

B 3.1.4 5 5

BASES ACTIONS (continued)

Continued operation is not allowed in the case of more than one CEA(s) 9 misaligned from any other CEA in its group by > [19 inches], or with one 3 or more full length CEAs inoperable. 7 5 5 SURVEILLANCE SR 3.1.4.1 REQUIREMENTS Verification that individual CEA positions are within [7 inches] (indicated 3 TSTF-reed switch positions) of all other CEAs in the group at a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 425-A Frequency allows the operator to detect a CEA that is beginning to deviate from its expected position. The specified Frequency takes into TSTF-account other CEA position information that is continuously available to 425-A INSERT 2 the operator in the control room, so that during actual CEA motion, deviations can immediately be detected.

5 5 SR 3.1.4.2 OPERABILITY of at least two CEA position indicator channels is required Not used. to determine CEA positions, and thereby ensure compliance with the CEA 8 alignment and insertion limits. The CEA full in and full out limits provide an additional independent means for determining the CEA positions when the CEAs are at either their fully inserted or fully withdrawn positions.

5 5 SR 3.1.4.3 Verifying each full length CEA is trippable would require that each CEA be tripped. In MODES 1 and 2 tripping each full length CEA would result in radial or axial power tilts, or oscillations. Therefore individual full length TSTF-CEAs are exercised every 92 days to provide increased confidence that 425-A all full length CEAs continue to be trippable, even if they are not regularly 3

tripped. A movement of [5 inches] is adequate to demonstrate motion without exceeding the alignment limit when only one full length CEA is being moved. The 92 day Frequency takes into consideration other TSTF-information available to the operator in the control room and other 425-A INSERT 2 surveillances being performed more frequently, which add to the determination of OPERABILITY of the CEAs (Ref. 7). Between required 5

performances of SR 3.1.4.3, if a CEA(s) is discovered to be immovable, 5

the CEA is considered to be OPERABLE. At anytime, if a CEA(s) is immovable, a determination of the trippability (OPERABILITY) of that CEA(s) must be made, and appropriate action taken.

CEOG STS B 3.1.4-7 Rev. 3.0, 03/31/04 1 5 San Onofre - Draft Revision XXX 5

Attachment 1, Volume 4, Rev. 0, Page 110 of 345

Attachment 1, Volume 4, Rev. 0, Page 111 of 345 B 3.1.5 TSTF-425-A INSERT 2 The Frequency is controlled under the Surveillance Frequency Control Program. 6

Reviewer's Note-------------------------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program 4 should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

Insert Page B 3.1.5-7 Attachment 1, Volume 4, Rev. 0, Page 111 of 345

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CEA Alignment (Digital)

B 3.1.4 5 5

BASES SURVEILLANCE REQUIREMENTS (continued) 5 SR 3.1.4.4 5 Performance of a CHANNEL FUNCTIONAL TEST of each reed switch 8 Not used.

position transmitter channel ensures the channel is OPERABLE and capable of indicating CEA position. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL FUNCTIONAL TEST of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. Since this test must be performed when the reactor is shut down, an 18 month Frequency to be coincident with refueling outage was selected.

Operating experience has shown that these components usually pass this Surveillance when performed at a Frequency of once every 18 months.

Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

5 5

SR 3.1.4.5 Verification of full length CEA drop times determines that the maximum CEA drop time permitted is consistent with the assumed drop time used 3

in the safety analysis (Ref. 7). Measuring drop times prior to reactor 1 criticality, after reactor vessel head removal, ensures the reactor internals and CEDM will not interfere with CEA motion or drop time, and that no degradation in these systems has occurred that would adversely affect CEA motion or drop time. Individual CEAs whose drop times are greater than safety analysis assumptions are not OPERABLE. This SR is performed prior to criticality due to the plant conditions needed to perform the SR and the potential for an unplanned plant transient if the Surveillance were performed with the reactor at power.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 10 and GDC 26.

2. 10 CFR 50.46. Sections 15.0.2 and15.4

3. FSAR, Section [ ]. 1 3 U

15.10.4.1.3

4. FSAR, Section [ ]. 3 U

CEOG STS B 3.1.4-8 Rev. 3.0, 03/31/04 1 5 San Onofre - Draft Revision XXX 5

Attachment 1, Volume 4, Rev. 0, Page 112 of 345

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CEA Alignment (Digital)

B 3.1.4 5 5

BASES REFERENCES (continued)

5. FSAR, Section [ ].

6. FSAR, Section [ ]. 3

7. FSAR, Section [ ].

CEOG STS B 3.1.4-9 Rev. 3.0, 03/31/04 1 55 San Onofre - Draft 5 Revision XXX Attachment 1, Volume 4, Rev. 0, Page 113 of 345

Attachment 1, Volume 4, Rev. 0, Page 114 of 345 JUSTIFICATION FOR DEVIATIONS ITS 3.1.5 BASES, CONTROL ELEMENT ASSEMBLY (CEA) ALIGNMENT

1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specification (ISTS) Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The headings for ISTS 3.1.4 (ITS 3.1.5) Bases include the parenthetical expression

"(Digital)." This identifying information is not included in the San Onofre Nuclear Generating Station (SONGS) ITS. This information is provided in the NUREG to assist in identifying the appropriate Specification to be used as a model for a plant specific ITS conversion, but serves no purpose in a plant specific ITS implementation. SONGS Units 2 and 3 are digital plants; therefore analog requirements and specific labels that identify a requirement is digital are not required.

3. The ISTS contains bracketed information and/or values that are generic to all Combustion Engineering vintage plants. The brackets are removed and the proper plant specific information/value is provided. This is acceptable since the information/value is revised to reflect the current licensing basis.

4. This "Reviewers Note" is being deleted. The Reviewers Note is for the NRC reviewer during the NRC review and will not be part of the plant specific SONGS ITS.

5. The Specification/SR number has been changed to be consistent with the Specification number in the SONGS CTS. SONGS CTS contained two SDM Specifications (CTS 3.1.1, SDM in MODES 3 and 4, and CTS 3.1.2, SDM in MODE 5) which are being combined into one Specification (ITS 3.1.1), consistent with NUREG-1432. SCE has decided not to renumber the CTS to be consistent with the ISTS because by doing so would result in the unnecessary administrative burden of changing TS numbers in plant procedures.

6. The Bases words changed by TSTF-425 have been modified to state "The Frequency is controlled under the Surveillance Frequency Control Program." The Surveillance Frequency Control Program provides the details for how to change the Frequencies, thus the TSTF-425 words concerning operating experience, equipment reliability, and plant risk is not always true for each of the Frequencies.

7. Opening the electrical circuit of the CEDM holding coil cannot result in an inadvertent withdrawal of a CEA. However, a malfunction in the CEDMCS or operator error can.

Therefore, the ISTS Bases words are changed to be consistent with the CTS Bases wording and what will actually cause an inadvertent CEA withdrawal.

8. ISTS SRs 3.1.4.2 and 3.1.4.4 have been moved from this Specification to a new ITS 3.1.15 (as SR 3.1.15.1 and SR 3.1.15.2). The SR numbers of the remaining SRs in this Specification have not been changed due to the deletion of these two SRs. SCE has decided not to renumber the CTS SRs because by doing so would result in the unnecessary administrative burden of changing TS numbers in plant procedures. For this reason, "Not used" SR numbers are also maintained in the ITS.

9. Changes have been made to the ACTIONS Bases to be consistent with changes made to the actual Specification. The proposed Bases wording for the ACTIONS reflects the requirements specified in the ITS ACTIONS, and the changes discussed in the Discussion of Changes for ITS 3.1.5.

San Onofre Unit 2 and 3 Page 1 of 2 Attachment 1, Volume 4, Rev. 0, Page 114 of 345

Attachment 1, Volume 4, Rev. 0, Page 115 of 345 JUSTIFICATION FOR DEVIATIONS ITS 3.1.5 BASES, CONTROL ELEMENT ASSEMBLY (CEA) ALIGNMENT

10. Changes are made to use correct punctuation, correct typographical errors or to make corrections consistent with the Writers Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01.

San Onofre Unit 2 and 3 Page 2 of 2 Attachment 1, Volume 4, Rev. 0, Page 115 of 345

Attachment 1, Volume 4, Rev. 0, Page 116 of 345 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 4, Rev. 0, Page 116 of 345

Attachment 1, Volume 4, Rev. 0, Page 117 of 345 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.1.5, CONTROL ELEMENT ASSEMBLY (CEA) ALIGNMENT There were no specific No Significant Hazards Considerations for this Specification.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 4, Rev. 0, Page 117 of 345

, Volume 4, Rev. 0, Page 118 of 345 ATTACHMENT 5 ITS 3.1.6, SHUTDOWN CEA INSERTION LIMITS , Volume 4, Rev. 0, Page 118 of 345

, Volume 4, Rev. 0, Page 119 of 345 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 4, Rev. 0, Page 119 of 345

Attachment 1, Volume 4, Rev. 0, Page 120 of 345 ITS Shutdown CEA Insertion Limits 3.1.6 A01 3.1 REACTIVITY CONTROL SYSTEMS 3.1.6 3.1.6 Shutdown Control Element Assembly (CEA) Insertion Limits LCO 3.1.6 LCO 3.1.6 All shutdown CEAs shall be withdrawn to $ 145 inches.

Applicability APPLICABILITY: MODE 1, MODE 2 with any regulating CEA not fully inserted.

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

This LCO is not applicable while performing SR 3.1.5.3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One or more shutdown A.1 Restore shutdown 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months CEA(s) not within CEA(s) to within limit. limit.

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

SAN ONOFRE--UNIT 2 3.1-12 Amendment No. 127,200 Attachment 1, Volume 4, Rev. 0, Page 120 of 345

Attachment 1, Volume 4, Rev. 0, Page 121 of 345 Shutdown CEA Insertion Limits ITS 3.1.6 A01 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.6.1 SR 3.1.6.1 Verify each shutdown CEA is withdrawn 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months LA01

$ 145 inches.

In accordance with the Surveillance Frequency Control Program SAN ONOFRE--UNIT 2 3.1-13 Amendment No. 127 Attachment 1, Volume 4, Rev. 0, Page 121 of 345

Attachment 1, Volume 4, Rev. 0, Page 122 of 345 ITS Shutdown CEA Insertion Limits 3.1.6 A01 3.1 REACTIVITY CONTROL SYSTEMS 3.1.6 3.1.6 Shutdown Control Element Assembly (CEA) Insertion Limits LCO 3.1.6 LCO 3.1.6 All shutdown CEAs shall be withdrawn to $ 145 inches.

Applicability APPLICABILITY: MODE 1, MODE 2 with any regulating CEA not fully inserted.

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

This LCO is not applicable while performing SR 3.1.5.3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One or more shutdown A.1 Restore shutdown 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months CEA(s) not within CEA(s) to within limit. limit.

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

SAN ONOFRE--UNIT 3 3.1-12 Amendment No. 116,191 Attachment 1, Volume 4, Rev. 0, Page 122 of 345

Attachment 1, Volume 4, Rev. 0, Page 123 of 345 Shutdown CEA Insertion Limits ITS 3.1.6 A01 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.6.1 SR 3.1.6.1 Verify each shutdown CEA is withdrawn 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months LA01

$ 145 inches.

In accordance with the Surveillance Frequency Control Program SAN ONOFRE--UNIT 3 3.1-13 Amendment No. 116 Attachment 1, Volume 4, Rev. 0, Page 123 of 345

Attachment 1, Volume 4, Rev. 0, Page 124 of 345 DISCUSSION OF CHANGES ITS 3.1.6, SHUTDOWN CEA INSERTION LIMITS ADMINISTRATIVE CHANGES A01 In the conversion of the San Onofre Nuclear Generating Station (SONGS)

Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1432, Rev. 3.0, "Standard Technical Specifications Combustion Engineering Plants" (ISTS) and additional approved Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 4 - Removal of LCO, SR, or other TS requirement to the LCS, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS SR 3.1.6.1 requires verification that each shutdown CEA is withdrawn 145 inches every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS SR 3.1.6.1 requires a similar Surveillance but specifies the periodic Frequency as "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequency to the Surveillance Frequency Control Program.

The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. In addition:

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program;

b. Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1; and San Onofre Unit 2 and 3 Page 1 of 4 Attachment 1, Volume 4, Rev. 0, Page 124 of 345

Attachment 1, Volume 4, Rev. 0, Page 125 of 345 DISCUSSION OF CHANGES ITS 3.1.6, SHUTDOWN CEA INSERTION LIMITS