Text

Attachment 1, Volume 5, San Onofre Nuclear Generating Station - Improved Technical Specifications Conversion - ITS Section 3.2, Power Distribution Limits
	ML11251A098
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: ML11251A098 (144)
	v • d • e

Attachment 1, Volume 5, Rev. 0, Page 1 of 144 ATTACHMENT 1 VOLUME 5 SAN ONOFRE NUCLEAR GENERATING STATION IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.2 POWER DISTRIBUTION LIMITS Attachment 1, Volume 5, Rev. 0, Page 1 of 144

Attachment 1, Volume 5, Rev. 0, Page 2 of 144 LIST OF ATTACHMENTS

1. ITS 3.2.1 - LINEAR HEAT RATE

2. ITS 3.2.2 - PLANAR RADIAL PEAKING FACTORS

3. ITS 3.2.3 - AZIMUTHAL TILT

4. ITS 3.2.4 - DEPARTURE FROM NUCLEATE BOILING RATIO

5. ITS 3.2.5 - AXIAL SHAPE INDEX Attachment 1, Volume 5, Rev. 0, Page 2 of 144

, Volume 5, Rev. 0, Page 3 of 144 ATTACHMENT 1 ITS 3.2.1, LINEAR HEAT RATE , Volume 5, Rev. 0, Page 3 of 144

Attachment 1, Volume 5, Rev. 0, Page 4 of 144 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 5, Rev. 0, Page 4 of 144

Attachment 1, Volume 5, Rev. 0, Page 5 of 144 ITS LHR 3.2.1 A01 3.2 POWER DISTRIBUTION LIMITS 3.2.1 3.2.1 Linear Heat Rate (LHR)

LCO 3.2.1 LCO 3.2.1 LHR shall not exceed the limits specified in the COLR.

Applicability APPLICABILITY: MODE 1 with THERMAL POWER > 20% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. Core operating limit A.1 Restore LHR to within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months supervisory system limits.

(COLSS) calculated core power exceeds the COLSS calculated core B .1 D eterm ine trend in LH R .

power operating limit AND based on LHR. B .2.1 W ith an adverse trend, restore LH R to within lim its.

OR Once per ACTION B B. With COLSS not in B.1 Initiate SR 3.2.1.2 15 minutes A02 service and any OPERABLE CPC local AND 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months LH R not within region of With no adverse trend, M01 acceptable operation power density channel exceeding the LHR B.2 Restore LHR to within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when C O LS S is out of M01 service limit. limits.

.2 ACTION C C. Required Action and C.1 Reduce THERMAL POWER 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months A03 associated Completion to # 20% RTP.

Time not met.

SAN ONOFRE--UNIT 2 3.2-1 Amendment No. 127 Attachment 1, Volume 5, Rev. 0, Page 5 of 144

Attachment 1, Volume 5, Rev. 0, Page 6 of 144 ITS LHR A01 3.2.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY required to be met SR 3.2.1.1 SR 3.2.1.1 -------------------NOTE--------------------

1. Only applicable when COLSS is out of A04 service. With COLSS in service, LHR is continuously monitored.

2. SR 3.0.4 is not applicable. A05 Verify LHR, as indicated on all OPERABLE 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months CPC local power density channels, is within COLR limits.

ACTION B SR 3.2.1.2 -------------------NOTE--------------------

Only applicable with LHR outside limit, as indicated by any OPERABLE CPC local power Not used. A02 density channel exceeding the LHR limit.

Verify no adverse trend in LHR. 15 minutes SR 3.2.1.3 SR 3.2.1.3 Verify the COLSS margin alarm actuates at a 31 days THERMAL POWER equal to or less than the core power operating limit based on LHR.

In accordance with the S urveillance Frequency LA01 C ontrol P rogram SAN ONOFRE--UNIT 2 3.2-2 Amendment No. 127 Attachment 1, Volume 5, Rev. 0, Page 6 of 144

Attachment 1, Volume 5, Rev. 0, Page 7 of 144 ITS LHR 3.2.1 A01 3.2 POWER DISTRIBUTION LIMITS 3.2.1 3.2.1 Linear Heat Rate (LHR)

LCO 3.2.1 LCO 3.2.1 LHR shall not exceed the limits specified in the COLR.

Applicability APPLICABILITY: MODE 1 with THERMAL POWER > 20% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. Core operating limit A.1 Restore LHR to within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months supervisory system limits.

(COLSS) calculated core power exceeds the COLSS calculated core B .1 D eterm ine trend in LH R .

power operating limit AND based on LHR. B .2.1 W ith an adverse trend, restore LH R to within lim its.

OR Once per ACTION B B. With COLSS not in B.1 Initiate SR 3.2.1.2 15 minutes A02 service and any OPERABLE CPC local AND 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months LH R not within region of With no adverse trend, M01 acceptable operation power density channel exceeding the LHR B.2 Restore LHR to within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when C O LS S is out of M01 service limit. limits.

.2 ACTION C C. Required Action and C.1 Reduce THERMAL POWER 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months A03 associated Completion to # 20% RTP.

Time not met.

SAN ONOFRE--UNIT 3 3.2-1 Amendment No. 116 Attachment 1, Volume 5, Rev. 0, Page 7 of 144

Attachment 1, Volume 5, Rev. 0, Page 8 of 144 ITS LHR A01 3.2.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY required to be met SR 3.2.1.1 SR 3.2.1.1 -------------------NOTE--------------------

1. Only applicable when COLSS is out of A04 service. With COLSS in service, LHR is continuously monitored.

2. SR 3.0.4 is not applicable. A05 Verify LHR, as indicated on all OPERABLE 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months CPC local power density channels, is within COLR limits.

ACTION B SR 3.2.1.2 -------------------NOTE--------------------

Only applicable with LHR outside limit, as indicated by any OPERABLE CPC local power Not used. A02 density channel exceeding the LHR limit.

Verify no adverse trend in LHR. 15 minutes SR 3.2.1.3 SR 3.2.1.3 Verify the COLSS margin alarm actuates at a 31 days THERMAL POWER equal to or less than the core power operating limit based on LHR.

In accordance with the S urveillance Frequency LA01 C ontrol P rogram SAN ONOFRE--UNIT 3 3.2-2 Amendment No. 116 Attachment 1, Volume 5, Rev. 0, Page 8 of 144

Attachment 1, Volume 5, Rev. 0, Page 9 of 144 DISCUSSION OF CHANGES ITS 3.2.1, LINEAR HEAT RATE 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 3.2.1 Required Action B.1 requires the initiation of SR 3.2.1.2 with COLSS not in service and the CPC local power density channel exceeding the LHR limit.

CTS SR 3.2.1.2 requires verifying no adverse trend in LHR every 15 minutes.

The SR contains a Note that modifies the SR to make it only applicable with LHR outside limits, as indicated by any OPERABLE CPC local power density channel exceeding the LHR limit. ITS Required Action B.1 requires the LHR trend to be determined every 15 minutes. This changes the CTS by deleting the SR and putting the requirements into the ACTIONS.

The application of this CTS SR 3.2.1.2 along with the Note that modified it is confusing and is more appropriately applied in the ACTIONS. The modified Completion Time is consistent with the current requirements. The proposed 15 minute Completion Time to determine the trend in LHR is consistent with the CTS Surveillance Frequency. This change appropriately incorporates a confusing SR that should be a Required Action into the ACTIONS. This change does not alter any of the requirements required by CTS 3.2.1 and is therefore administrative.

A03 CTS 3.2.1 Condition B states, "With COLSS not in service and any OPERABLE CPC local power density channel exceeding the LHR limit." ITS 3.2.1 Condition B states, "LHR not within region of acceptable operation when COLSS is out of service." This changes the CTS by stating that the LCO is not met (i.e., LHR is not within the region of acceptable operation) in the first part of the Condition.

The proposed change rewords the Condition to be consistent with NUREG-1432 without changing the intent. This is an administrative change which clarifies the wording of the Condition to align with the adverse condition that exists.

A04 CTS SR 3.2.1.1 contains a Note (Note 1) which modifies the SR by making it only "applicable" when COLSS is out of service. ITS SR 3.2.1.1 revises the Note to be only "required to be met" when COLSS is out of service. This changes the CTS by clarifying what applicable means (i.e., not required to be met) based on the changes to Section 1.4, and deleting the SR 3.0.4 allowance.

TSTF-284 revised CTS Section 1.4 to add a discussion regarding the use of "met" and "perform" in SR Notes and adds examples to facilitate the use and application of SR Notes that utilize "met" and "perform." The TSTF also revises SR Notes, as necessary, to appropriately clarify the use of "met" and "perform" San Onofre Unit 2 and 3 Page 1 of 5 Attachment 1, Volume 5, Rev. 0, Page 9 of 144

Attachment 1, Volume 5, Rev. 0, Page 10 of 144 DISCUSSION OF CHANGES ITS 3.2.1, LINEAR HEAT RATE exceptions. The SONGS CTS do not contain this detail; however, various locations throughout the TS provide Notes with "met" and "performed" distinctions. This change does not change the intent of any SR Note. This proposed change will provide for better use, application, and understanding of this Note along with the changes to Section 1.4. This is an administrative change which clarifies and corrects exceptions that are unclear or have incorrect usage of "met" and "perform."

A05 CTS SR 3.2.1.1 contains the Note (Note 2) that SR 3.0.4 is not applicable. ITS SR 3.2.1.1 does not contain this Note. This changes the CTS by deleting this specific Note.

The purpose of the Note 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 ITS SR 3.2.1.1 remaining Note (first sentence),

which states, "Only required to be met when COLSS is out of service," is written to allow entry into MODE 1 following a reactor startup. This serves the same purpose as the existing CTS Note 2 and is described in CTS and ITS SR 3.0.4.

Thus the Note is redundant and has been deleted. This change is designated as administrative because it eliminates a CTS provision which is not required because it is already allowed by the SR.

MORE RESTRICTIVE CHANGES M01 CTS 3.2.1 Required Action B.1 requires the initiation of SR 3.2.1.2 if the COLSS is out of service and any OPERABLE CPC local power density channel exceeds the LHR limit. CTS SR 3.2.1.2 requires verification of no adverse trend in LHR every 15 minutes. However, this is done to monitor LHR, and no specific actions are required except to restore the LHR to within limits in 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , as stated in CTS 3.2.1 Required Action B.2. Under similar conditions, if an adverse trend is detected, ITS 3.2.1 Required Action B.2.1 requires restoration of the LHR to within limits in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . If no adverse trend is detected, ITS 3.2.1 Required Action B.2.2 continues to require the LHR to be restored to within limits within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

This changes the CTS by requiring restoration of LHR to within the limits in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months if an adverse trend is detected, in lieu of the current 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

The purpose of ITS 3.2.1 Required Action B.2.1 is to require restoration of the LHR to within limits in a time consistent with ITS 3.2.1 Required Action A.1, when an adverse trend in LHR is detected. This change is acceptable because the unit will be allowed to operate for a shorter period of time (1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ) if an adverse trend is detected. This ensures that reductions in reactor power occur sooner when an adverse trend is detected. This change is designated as more restrictive because less time is allowed to restore LHR to within limits when an adverse trend is detected with the COLSS not in service.

RELOCATED SPECIFICATIONS None San Onofre Unit 2 and 3 Page 2 of 5 Attachment 1, Volume 5, Rev. 0, Page 10 of 144

Attachment 1, Volume 5, Rev. 0, Page 11 of 144 DISCUSSION OF CHANGES ITS 3.2.1, LINEAR HEAT RATE 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 3.2.1.1 requires verification that LHR, as indicated on all OPERABLE CPC local power density channels, is within COLR limits every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . CTS SR 3.2.1.3 requires verification the COLSS margin alarm actuates at a THERMAL POWER equal to or less than the core power operating limit based on LHR every 31 days. ITS SR 3.2.1.1 and ITS SR 3.2.1.3 require similar Surveillances, respectively, 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 SRs and the Bases for the Frequencies 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.

San Onofre Unit 2 and 3 Page 3 of 5 Attachment 1, Volume 5, Rev. 0, Page 11 of 144

Attachment 1, Volume 5, Rev. 0, Page 12 of 144 DISCUSSION OF CHANGES ITS 3.2.1, LINEAR HEAT RATE

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.

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.

San Onofre Unit 2 and 3 Page 4 of 5 Attachment 1, Volume 5, Rev. 0, Page 12 of 144

Attachment 1, Volume 5, Rev. 0, Page 13 of 144 DISCUSSION OF CHANGES ITS 3.2.1, LINEAR HEAT RATE 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 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.

LESS RESTRICTIVE CHANGES None San Onofre Unit 2 and 3 Page 5 of 5 Attachment 1, Volume 5, Rev. 0, Page 13 of 144

Attachment 1, Volume 5, Rev. 0, Page 14 of 144 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 5, Rev. 0, Page 14 of 144

Attachment 1, Volume 5, Rev. 0, Page 15 of 144 U2/U3 CTS LHR (Digital) 2 3.2.1 3.2 POWER DISTRIBUTION LIMITS 3.2.1 Linear Heat Rate (LHR) (Digital) 2 LCO 3.2.1 LCO 3.2.1 LHR shall not exceed the limits specified in the COLR.

Applicability APPLICABILITY: MODE 1 with THERMAL POWER > 20% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. Core Operating Limit A.1 Restore LHR to within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Supervisory System limits.

(COLSS) calculated core power exceeds the COLSS calculated core power operating limit based on LHR.

ACTION B, B. LHR not within region of B.1 Determine trend in LHR. Once per 15 minutes SR 3.2.1.2 acceptable operation when the COLSS is out AND of service.

B.2.1 With an adverse trend, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months restore LHR to within limit. 4 s

OR B.2.2 With no adverse trend, 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months restore LHR to within limits.

ACTION C, SR 3.2.1.2 C. Required Action and C.1 Reduce THERMAL 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion POWER to 20% RTP.

Time not met.

CEOG STS 3.2.1-1 Amendment XXX Rev. 3.0, 03/31/04 1 San Onofre - Draft Attachment 1, Volume 5, Rev. 0, Page 15 of 144

Attachment 1, Volume 5, Rev. 0, Page 16 of 144 U2/U3 CTS LHR (Digital) 2 3.2.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 SR 3.2.1.1 -------------------------------NOTE------------------------------

Only required to be met when COLSS is out of service. With COLSS in service, LHR is continuously monitored.

TSTF-Verify LHR, as indicated on each OPERABLE local 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 425-A power density channel, is within its limit.

TSTF-SR 3.2.1.3 SR 3.2.1.2 Verify the COLSS margin alarm actuates at a 31 days 3 425-A THERMAL POWER equal to or less than the core 3

power operating limit based on LHR. In accordance with the Surveillance Frequency Control Program SR 3.2.1.2 3 Not used.

CEOG STS 3.2.1-2 Amendment XXX Rev. 3.0, 03/31/04 1 San Onofre - Draft Attachment 1, Volume 5, Rev. 0, Page 16 of 144

Attachment 1, Volume 5, Rev. 0, Page 17 of 144 JUSTIFICATION FOR DEVIATIONS ITS 3.2.1, LINEAR HEAT RATE

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 3.2.1 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. The SR number has been changed to be consistent with the SR number in the SONGS CTS. 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 SR numbers in plant procedures. For this reason, "Not used" SR numbers are also maintained in the ITS.

4. An "s" was added to "limit" in ISTS 3.2.1 Required Action B.2.1 to correct a typographical error because both Required Actions A.1 and B.2.2 use the term "limits."

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 5, Rev. 0, Page 17 of 144

Attachment 1, Volume 5, Rev. 0, Page 18 of 144 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 5, Rev. 0, Page 18 of 144

Attachment 1, Volume 5, Rev. 0, Page 19 of 144 LHR (Digital) 3 B 3.2.1 B 3.2 POWER DISTRIBUTION LIMITS B 3.2.1 Linear Heat Rate (LHR) (Digital) 3 BASES BACKGROUND The purpose of this LCO is to limit the core power distribution to the initial values assumed in the accident analyses. Operation within the limits imposed by this LCO limits or prevents potential fuel cladding failures that could breach the primary fission product barrier and release fission products to the reactor coolant in the event of a loss of coolant accident (LOCA), loss of flow accident, ejected control element assembly (CEA) accident, or other postulated accident requiring termination by a Reactor 1

Protective Protection System (RPS) trip function. This LCO limits the damage to the fuel cladding during an accident by ensuring that the plant is operating within acceptable bounding conditions at the onset of a transient.

Methods of controlling the power distribution include:

a. Using full or part length CEAs to alter the axial power distribution,

b. Decreasing CEA insertion by boration, thereby improving the radial power distribution, and

c. Correcting off optimum conditions (e.g., a CEA drop or misoperation of the unit) that cause margin degradations.

The core power distribution is controlled so that, in conjunction with other core operating parameters (e.g., CEA insertion and alignment limits), the power distribution does not result in violation of this LCO. The limiting safety system settings and this LCO are based on the accident analyses (Refs. 1 and 2), so that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences (AOOs), and the limits of acceptable consequences are not exceeded for other postulated accidents.

Limiting power distribution skewing over time also minimizes xenon distribution skewing, which is a significant factor in controlling the axial power distribution.

Power distribution is a product of multiple parameters, various combinations of which may produce acceptable power distributions.

Operation within the design limits of power distribution is accomplished by generating operating limits on the LHR and departure from nucleate boiling (DNB).

1 CEOG STS San Onofre - Draft B 3.2.1-1 Revision XXX Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 19 of 144

Attachment 1, Volume 5, Rev. 0, Page 20 of 144 3

LHR (Digital)

B 3.2.1 BASES BACKGROUND (continued)

Proximity to the DNB condition is expressed by the departure from nucleate boiling ratio (DNBR), defined as the ratio of the cladding surface heat flux required to cause DNB to the actual cladding surface heat flux.

The minimum DNBR value during both normal operation and AOOs is calculated by the CE-1 Correlation (Ref. 3) and corrected for such factors as rod bow and grid spacers. It is accepted as an appropriate margin to DNB for all operating conditions.

There are two systems that monitor core power distribution online: the Core Operating Limit Supervisory System (COLSS) and the core protection calculators (CPCs). The COLSS and CPCs that monitor the core power distribution are capable of verifying that the LHR and the DNBR do not exceed their limits. The COLSS performs this function by continuously monitoring the core power distribution and calculating core power operating limits corresponding to the allowable peak LHR and DNBR. The CPCs perform this function by continuously calculating an actual value of DNBR and local power density (LPD) for comparison with the respective trip setpoints.

A DNBR penalty factor is included in both the COLSS and CPC DNBR calculations to accommodate the effects of rod bow. The amount of rod bow in each assembly is dependent upon the average burnup experienced by that assembly. Fuel assemblies that incur higher than average burnup experience a greater magnitude of rod bow. Conversely, fuel assemblies that receive lower than average burnup experience less rod bow. In design calculations for a reload core, each batch of fuel is assigned a penalty applied to the maximum integrated planar radial power peak of the batch. This penalty is correlated with the amount of rod bow determined from the maximum average assembly burnup of the batch. A single net penalty for the COLSS and CPCs is then determined from the penalties associated with each batch that comprises a core reload, accounting for the offsetting margins due to the lower radial power peaks in the higher burnup batches.

The COLSS indicates continuously to the operator how far the core is from the operating limits and provides an audible alarm if an operating limit is exceeded. Such a condition signifies a reduction in the capability of the plant to withstand an anticipated transient, but does not necessarily imply an immediate violation of fuel design limits. If the margin to fuel design limits continues to decrease, the RPS ensures that the specified acceptable fuel design limits are not exceeded during AOOs by initiating reactor trips.

1 CEOG STS San Onofre - Draft B 3.2.1-2 Revision XXX Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 20 of 144

Attachment 1, Volume 5, Rev. 0, Page 21 of 144 3

LHR (Digital)

B 3.2.1 BASES BACKGROUND (continued)

The COLSS continually generates an assessment of the calculated margin for specified LHR and DNBR limits. The data required for these assessments include measured incore neutron flux, CEA positions, and Reactor Coolant System (RCS) inlet temperature, pressure, and flow.

In addition to the monitoring performed by the COLSS, the RPS (via the CPCs) continually infers the core power distribution and thermal margins by processing reactor coolant data, signals from excore neutron flux detectors, and input from redundant reed switch assemblies that indicate CEA positions. In this case, the CPCs assume a minimum core power of 20% RTP because the power range excore neutron flux detecting system is inaccurate below this power level. If power distribution or other parameters are perturbed as a result of an AOO, the high LPD or low DNBR trips in the RPS initiate a reactor trip prior to the exceeding of fuel design limits.

The LHR and DNBR algorithms are valid within the limits on ASI, Fxy and Tq TQ. These limits are obtained directly from initial core or reload analysis. 5 APPLICABLE The fuel cladding must not sustain damage as a result of normal SAFETY operation or AOOs (Ref. 4).

ANALYSES The power distribution and CEA insertion and alignment LCOs prevent core power distributions from reaching levels that violate the following fuel design criteria:

a. During a LOCA, peak cladding temperature must not exceed 2200°F (Ref. 5),

b. During a loss of flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel rod in the core does not experience a DNB condition (Ref. 4), 1 Refs. 6 and 7

c. During an ejected CEA accident, the fission energy input to the fuel must not exceed 280 cal/gm (Ref. [ ]), and 4 Refs. 8 and 9

d. The control rods must be capable of shutting down the reactor with a minimum required SDM with the highest worth control rod stuck fully withdrawn (GDC 26, Ref. [ ]). 4 10 1

CEOG STS San Onofre - Draft B 3.2.1-3 Revision XXX Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 21 of 144

Attachment 1, Volume 5, Rev. 0, Page 22 of 144 LHR (Digital) 3 B 3.2.1 BASES APPLICABLE SAFETY ANALYSES (continued) 1, ,

The power density at any point in the core must be limited to maintain the 1 fuel design criteria (Refs. 4 and 5). This is accomplished by maintaining the power distribution and reactor coolant conditions so that the peak LHR and DNB parameters are within operating limits supported by the accident analyses (Ref. 1) with due regard for the correlations between measured quantities, the power distribution, and uncertainties in determining the power distribution.

Fuel cladding failure during a LOCA is limited by restricting the maximum linear heat generation rate so that the peak cladding temperature does not exceed 2200°F (Ref. 5). Peak cladding temperatures exceeding 2200°F cause severe cladding failure by oxidation due to a Zircaloy water reaction.

The LCOs governing the LHR, ASI, and RCS ensure that these criteria are met as long as the core is operated within the ASI and Fxy limits 5

specified in the COLR, and within the TQ limits. The latter are process variables that characterize the three dimensional power distribution of the reactor core. Tq Operation within the limits for these variables ensures that their actual values are within the ranges used in the accident analyses.

Fuel cladding damage does not normally occur from conditions outside the limits of these LCOs during normal operation. However, fuel cladding damage could result if an accident or AOO occurs from initial conditions outside the limits of these LCOs. This potential for fuel cladding damage exists because changes in the power distribution can cause increased power peaking and can correspondingly increase local LHR.

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

LCO The power distribution LCO limits are based on correlations between power peaking and certain measured variables used as inputs to the LHR and DNBR operating limits. The power distribution LCO limits are provided in the COLR. The limitation on LHR ensures that in the event of a LOCA the peak temperature of the fuel cladding does not exceed 2200°F.

CEOG STS San Onofre - Draft B 3.2.1-4 Revision XXX Rev. 3.0, 03/31/04 1 Attachment 1, Volume 5, Rev. 0, Page 22 of 144

Attachment 1, Volume 5, Rev. 0, Page 23 of 144 LHR (Digital) 3 B 3.2.1 BASES APPLICABILITY Power distribution is a concern any time the reactor is critical. The power distribution LCOs, however, are only applicable in MODE 1 above 20% RTP. The reasons these LCOs are not applicable below 20% RTP are:

a. The incore neutron detectors that provide input to the COLSS, which then calculates the operating limits, are inaccurate due to the poor signal to noise ratios at relatively low core power levels and

b. As a result of this inaccuracy, the CPCs assume minimum core power of 20% RTP when generating LPD and DNBR trip signals.

When core power is below 20% RTP, the core is operating well below its thermal limits and the resultant CPC calculated LPD and DNBR trips are highly conservative.

ACTIONS A.1 Operation at or below the COLSS calculated power limit based on the LHR ensures that the LHR limit is not exceeded. If the COLSS calculated core power limit based on the LHR exceeds the operating limit, restoring the LHR to within limit in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months ensures that prompt action is taken to reduce LHR to below the specified limit. One hour is a reasonable time to return LHR to within limits when the limit is exceeded without a trip due to events such as a dropped CEA or an axial xenon oscillation.

B.1, B.2.1, and B.2.2 If the COLSS is not available the OPERABLE LPD channels are monitored to ensure that the LHR limit is not exceeded. Operation within this limit ensures that in the event of a LOCA the fuel cladding temperature does not exceed 2200°F. Four hours is allowed for restoring the LHR limit to within the region of acceptable operation. This duration is reasonable because the COLSS allows the plant to operate with less LHR margin (closer to the LHR limit than when monitoring the CPCs).

When operating with the COLSS out of service there is a possibility of a slow undetectable transient that degrades the LHR slowly over the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months period and is then followed by an AOO or an accident. To remedy this, the CPC calculated values of LHR are monitored every 15 minutes when the COLSS is out of service. The 15 minute Frequency is adequate to allow the operator to identify an adverse trend in conditions that could result in an approach to the LHR limit. Also, a maximum allowable 1

CEOG STS San Onofre - Draft B 3.2.1-5 Revision XXX Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 23 of 144

Attachment 1, Volume 5, Rev. 0, Page 24 of 144 LHR (Digital) 3 B 3.2.1 BASES ACTIONS (continued) change in the CPC calculated LHR ensures that further degradation requires the operators to take immediate action to restore LHR to within limits or reduce reactor power to comply with the Technical Specifications (TS). With an adverse trend, 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is allowed for restoring LHR to within limits if the COLSS is not restored to OPERABLE status. Implementation of this requirement ensures that reductions in core thermal margin are quickly detected, and if necessary, results in a decrease in reactor power and subsequent compliance with the existing COLSS out of service TS limits.

With no adverse trend, 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is allowed to restore the LHR to within limits if the COLSS is not restored to OPERABLE status. This duration is reasonable because the Frequency of the CPC determination of LHR is increased and if operation is maintained steady, the likelihood of exceeding the LHR limit during this period is not increased. The likelihood of induced reactor transients from an early power reduction is also decreased.

C.1 If the LHR cannot be returned to within its limit or the LHR cannot be determined because of the COLSS and CPC inoperability, core power must be reduced. Reduction of core power to < 20% RTP ensures that the core is operating within its thermal limits and places the core in a conservative condition based on the trip setpoints generated by the CPCs, which assume a minimum core power of 20% RTP. 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, to reach 20% RTP in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.2.1.1 REQUIREMENTS With the COLSS out of service, the operator must monitor the LHR with each OPERABLE local power density channel. A 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Frequency is INSERT 1 sufficient to allow the operator to identify trends that would result in an TSTF-425-A approach to the LHR limits.

This SR is modified by a Note that states that the SR is only required to be met when the COLSS is out of service. Continuous monitoring of the LHR is provided by the COLSS, which calculates core power and core power operating limits based on the LHR and continuously displays these limits to the operator. A COLSS margin alarm is annunciated in the event that the THERMAL POWER exceeds the core power operating limit based on LHR.

1 CEOG STS San Onofre - Draft B 3.2.1-6 Revision XXX Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 24 of 144

Attachment 1, Volume 5, Rev. 0, Page 25 of 144 B 3.2.1 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 should utilize the appropriate Frequency description, given above, and the appropriate choice of 6 Frequency in the Surveillance Requirement.

Insert Page B 3.2.1-6 Attachment 1, Volume 5, Rev. 0, Page 25 of 144

Attachment 1, Volume 5, Rev. 0, Page 26 of 144 3

LHR (Digital)

B 3.2.1 BASES SURVEILLANCE REQUIREMENTS (continued) SR 3.2.1.2 8

Not used.

SR 3.2.1.2 3 Verification that the COLSS margin alarm actuates at a THERMAL POWER level equal to or less than the core power operating limit based on the LHR in units of kilowatts per foot ensures the operator is alerted when conditions approach the LHR operating limit.

The 31 day Frequency for performance of this SR is consistent with the historical testing frequency of reactor protection and monitoring systems.

TSTF-INSERT 1 The Surveillance Frequency for testing protection systems was extended 425-A to 92 days by CEN 327. Monitoring systems were not addressed in CEN 327; therefore, this Frequency remains at 31 days.

REFERENCES 1. FSAR, Section [15].

U Chapter 1 4

2. FSAR, Section [6].

3. CE-1 Correlation for DNBR.

4. 10 CFR 50.46, Appendix A, GDC 10. 2

5. 10 CFR 50.46.

1

6. UFSAR, Section 4.4.1.1.

7. UFSAR, Table 15.0-8.

8. UFSAR, Section 15.4.3.2.

9. UFSAR, Section 15.10. 4.3.2.

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

CEOG STS B 3.2.1-7 Revision XXX Rev. 3.0, 03/31/04 1 San Onofre - Draft Attachment 1, Volume 5, Rev. 0, Page 26 of 144

Attachment 1, Volume 5, Rev. 0, Page 27 of 144 B 3.2.1 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 should utilize the appropriate Frequency description, given above, and the appropriate choice of 6 Frequency in the Surveillance Requirement.

Insert Page B 3.2.1-7 Attachment 1, Volume 5, Rev. 0, Page 27 of 144

Attachment 1, Volume 5, Rev. 0, Page 28 of 144 JUSTIFICATION FOR DEVIATIONS ITS 3.2.1 BASES, LINEAR HEAT RATE

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 reference to 10 CFR 50.46 Appendix A, GDC 10 is being corrected to 10 CFR 50 Appendix A, GDC 10. The GDC's are located in 10 CFR 50 Appendix A and 10 CFR 50.46 does not contain an Appendix A.

3. The headings for ISTS 3.2.1 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.

4. 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 changed to reflect the current licensing basis.

5. 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.

6. 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.

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 are not always true for each of the Frequencies.

8. Changes are made to the Bases to be consistent with changes made to the actual Specifications.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 5, Rev. 0, Page 28 of 144

Attachment 1, Volume 5, Rev. 0, Page 29 of 144 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 5, Rev. 0, Page 29 of 144

Attachment 1, Volume 5, Rev. 0, Page 30 of 144 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.1, LINEAR HEAT RATE There are no specific No Significant Hazards Considerations for this Specification.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 5, Rev. 0, Page 30 of 144

Attachment 1, Volume 5, Rev. 0, Page 31 of 144 ATTACHMENT 2 ITS 3.2.2, PLANAR RADIAL PEAKING FACTORS (Fxy)

Attachment 1, Volume 5, Rev. 0, Page 31 of 144

, Volume 5, Rev. 0, Page 32 of 144 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 5, Rev. 0, Page 32 of 144

Attachment 1, Volume 5, Rev. 0, Page 33 of 144 F xy ITS 3.2.2 A01 3.2 POWER DISTRIBUTION LIMITS 3.2.2 3.2.2 Planar Radial Peaking Factors (F xy)

LCO 3.2.2 LCO 3.2.2 The measured Planar Radial Peaking Factors (F Mxy) shall be less than or equal to the Planar Radial Peaking Factors (F Cxy) used in the Core Operating Limit Supervisory System (COLSS) and in the Core Protection Calculators (CPCs).

Applicability APPLICABILITY: MODE 1 with THERMAL POWER > 20% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. M Fxy C A.1 Adjust the CPC 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ACTION A > Fxy.

addressable constants

.1 to increase the multiplier applied to planar radial peaking by a factor $ FxyM C

/Fxy.

AND A.1.1 Adjust the affected 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months L01 C

Fxy used in the COLSS 2 to a value greater and C P C s than or equal to the measured Fxy M OR L01 A.1.2 Maintain a margin to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months the COLSS operating limits of M

[(Fxy C

/Fxy)-1.0]

x 100%.

OR .3 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months A.2 Reduce THERMAL POWER to < 20% RTP.

SAN ONOFRE--UNIT 2 3.2-3 Amendment No. 127 Attachment 1, Volume 5, Rev. 0, Page 33 of 144

Attachment 1, Volume 5, Rev. 0, Page 34 of 144 F xy 3.2.2 ITS A01 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

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

SR 3.0.4 is not applicable. A02 SR 3.2.2.1 SR 3.2.2.1 M Verify measured Fxy Once after each obtained using the Incore Detector System is less than or fuel loading C

equal to the value of Fxy with THERMAL used in the COLSS and CPCs. POWER > 40% RTP but prior to Thermal POWER A01

>85% RTP operations above AND In accordance with 31 EFPD the S urveillance thereafter Frequency C ontrol P rogram LA01 SAN ONOFRE--UNIT 2 3.2-4 Amendment No. 127 Attachment 1, Volume 5, Rev. 0, Page 34 of 144

Attachment 1, Volume 5, Rev. 0, Page 35 of 144 F xy ITS 3.2.2 A01 3.2 POWER DISTRIBUTION LIMITS 3.2.2 3.2.2 Planar Radial Peaking Factors (F xy)

LCO 3.2.2 LCO 3.2.2 The measured Planar Radial Peaking Factors (F Mxy) shall be less than or equal to the Planar Radial Peaking Factors (F Cxy) used in the Core Operating Limit Supervisory System (COLSS) and in the Core Protection Calculators (CPCs).

Applicability APPLICABILITY: MODE 1 with THERMAL POWER > 20% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. M Fxy C A.1 Adjust the CPC 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ACTION A > Fxy.

addressable constants

.1 to increase the multiplier applied to planar radial peaking by a factor $ FxyM C

/Fxy.

AND A.1.1 Adjust the affected 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months L01 C

Fxy used in the COLSS 2 to a value greater and C P C s than or equal to the measured Fxy M OR L01 A.1.2 Maintain a margin to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months the COLSS operating limits of M

[(Fxy C

/Fxy)-1.0]

x 100%.

OR .3 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months A.2 Reduce THERMAL POWER to < 20% RTP.

SAN ONOFRE--UNIT 3 3.2-3 Amendment No. 116 Attachment 1, Volume 5, Rev. 0, Page 35 of 144

Attachment 1, Volume 5, Rev. 0, Page 36 of 144 F xy 3.2.2 ITS A01 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

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

SR 3.0.4 is not applicable. A02 SR 3.2.2.1 SR 3.2.2.1 M Verify measured Fxy Once after each obtained using the Incore Detector System is less than or fuel loading C

equal to the value of Fxy with THERMAL used in the COLSS and CPCs. POWER > 40% RTP but prior to Thermal POWER A01

>85% RTP operations above AND In accordance with 31 EFPD the S urveillance thereafter Frequency C ontrol P rogram LA01 SAN ONOFRE--UNIT 3 3.2-4 Amendment No. 116 Attachment 1, Volume 5, Rev. 0, Page 36 of 144

Attachment 1, Volume 5, Rev. 0, Page 37 of 144 DISCUSSION OF CHANGES ITS 3.2.2, PLANAR RADIAL PEAKING FACTORS (Fxy)

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 3.2.2.1 contains the Note that SR 3.0.4 is not applicable. ITS SR 3.2.2.1 does not contain this Note. This changes the CTS by deleting this specific note.

The purpose of the Note 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 ITS SR 3.2.2.1 Frequency is written to allow entry into MODE 1 following a reactor startup. This serves the same purpose as the Note and is described in CTS and ITS SR 3.0.4. Thus the Note is redundant and has been deleted. 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 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 3.2.2.1 requires the measured Fxy to be less than the calculated Fxy to be performed every 31 EFPD after the initial startup performance. ITS SR 3.2.2.1 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 31 EFPD Frequency and the Bases for the Frequencies 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 San Onofre Unit 2 and 3 Page 1 of 5 Attachment 1, Volume 5, Rev. 0, Page 37 of 144

Attachment 1, Volume 5, Rev. 0, Page 38 of 144 DISCUSSION OF CHANGES ITS 3.2.2, PLANAR RADIAL PEAKING FACTORS (Fxy)

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 Surveillance Requirements themselves will remain in TS. This is consistent with other NRC approved TS changes in which the Surveillance Frequencies San Onofre Unit 2 and 3 Page 2 of 5 Attachment 1, Volume 5, Rev. 0, Page 38 of 144

Attachment 1, Volume 5, Rev. 0, Page 39 of 144 DISCUSSION OF CHANGES ITS 3.2.2, PLANAR RADIAL PEAKING FACTORS (Fxy) 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 5, Rev. 0, Page 39 of 144

Attachment 1, Volume 5, Rev. 0, Page 40 of 144 DISCUSSION OF CHANGES ITS 3.2.2, PLANAR RADIAL PEAKING FACTORS (Fxy)

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 L01 (Category 4 - Relaxation of Required Action) CTS 3.2.2 Required Actions A.1, A.1.1, and A.1.2, when the measured planar radial peaking factors (Fxy) are greater than the calculated, require an adjustment of the CPC addressable constants to adjust the multiplier applied to the Fxy; and an adjustment of the calculated Fxy used in the COLSS or a requirement to maintain a margin to the COLSS operating limit. ITS 3.2.2 ACTION A will require an adjustment of the CPC addressable constants and a requirement to maintain a margin to the COLSS operating limit; or a requirement to adjust the calculated Fxy used in the COLSS and CPCs. This changes the CTS by not requiring an adjustment of the CPC addressable constants when an adjustment to the calculated Fxy used in the COLSS and CPCs is performed.

The purpose of ACTION A is to compensate for the potential of nonconservative operating limits and trip setpoints when the measured Fxy > calculated Fxy. This change allows the adjustment of the CPC addressable constants to increase the multiplier applied to planar radial to not be performed in all cases. Specifically, it allows only an adjustment of the calculated Fxy, used in the COLSS and CPCs to values measured Fxy. This adjustment adequately compensates for the San Onofre Unit 2 and 3 Page 4 of 5 Attachment 1, Volume 5, Rev. 0, Page 40 of 144

Attachment 1, Volume 5, Rev. 0, Page 41 of 144 DISCUSSION OF CHANGES ITS 3.2.2, PLANAR RADIAL PEAKING FACTORS (Fxy) measured Fxy values exceeding the calculated Fxy values, and performs a similar function as the adjustment of addressable constants. This change will continue to ensure appropriate steps are taken to reduce the calculated Fxy to less than the measured Fxy to ensure COLSS operating limits and CPC trip setpoints remain valid with respect to the accident analysis. Therefore, this change is considered acceptable. This change is designated a less restrictive change because a Required Action has been deleted from the CTS.

San Onofre Unit 2 and 3 Page 5 of 5 Attachment 1, Volume 5, Rev. 0, Page 41 of 144

Attachment 1, Volume 5, Rev. 0, Page 42 of 144 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 5, Rev. 0, Page 42 of 144

Attachment 1, Volume 5, Rev. 0, Page 43 of 144 U2/U3 CTS Fxy (Digital) 2 3.2.2 3.2 POWER DISTRIBUTION LIMITS 3.2.2 Planar Radial Peaking Factors (Fxy) (Digital) 2 M

LCO 3.2.2 LCO 3.2.2 The measured Planar Radial Peaking Factors ( Fxy ) shall be equal to or C

less than the Planar Radial Peaking Factors ( Fxy ). (These factors are used in the Core Operating Limit Supervisory System (COLSS) and in the Core Protection Calculators (CPCs)).

Applicability APPLICABILITY: MODE 1 with THERMAL POWER > 20% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A M C A. Fxy > Fxy . A.1.1 Adjust addressable CPC 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months constants to increase the multiplier applied to planar radial peaking by a factor M C Fxy / Fxy .

AND A.1.2 Maintain a margin to the 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months COLSS operating limits of M C

[( Fxy / Fxy )-1.0] x 100%

OR C

A.2 Adjust the affected Fxy 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months used in the COLSS and CPCs to a value greater than or equal to the M

measured Fxy .

OR A.3 Reduce THERMAL 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months POWER to 20% RTP.

CEOG STS San Onofre - Draft 3.2.2-1 Amendment XXX Rev. 3.0, 03/31/04 1 Attachment 1, Volume 5, Rev. 0, Page 43 of 144

Attachment 1, Volume 5, Rev. 0, Page 44 of 144 U2/U3 CTS Fxy (Digital) 2 3.2.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY M

SR 3.2.2.1 SR 3.2.2.1 Verify measured Fxy obtained using the Incore Once after each Detector System is equal to or less than the value of fuel loading with C

Fxy used in the COLSS and CPCs. THERMAL POWER

> 40% RTP but prior to operations above 70% RTP 3 85 AND 31 EFPD TSTF-425-A thereafter In accordance with the Surveillance Frequency Control Program 1

CEOG STS San Onofre - Draft 3.2.2-2 Amendment XXX Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 44 of 144

Attachment 1, Volume 5, Rev. 0, Page 45 of 144 JUSTIFICATION FOR DEVIATIONS ITS 3.2.2, PLANAR RADIAL PEAKING FACTORS (Fxy)

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 3.2.2 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 3.2.2.1 is required to be performed prior to exceeding 70% RTP after each fuel loading. This upper limit has been changed to 85% RTP, consistent with the current allowance in SONGS CTS SR 3.2.2.1. This allows testing the shape annealing matrixes. Furthermore, conservative values are inserted for the CPC uncertainty prior to initial startup, and these conservative values ensure protection capability of the CPCs and allow operation up to 85% RTP. This allowance was approved by the NRC as part of the original conversion to the ISTS format. The 85%

RTP value is also consistent with Surveillances in CTS 3.3.1 (SRs 3.3.1.3, 3.3.1.5, and 3.3.1.11) that verify the CPCs are OPERABLE (as approved by the NRC in the safety evaluation for Units 2 and 3 Amendments 127 and 116, respectively, dated February 9, 1996 (ADAMS Accession No. ML021990684)).

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 5, Rev. 0, Page 45 of 144

Attachment 1, Volume 5, Rev. 0, Page 46 of 144 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 5, Rev. 0, Page 46 of 144

Attachment 1, Volume 5, Rev. 0, Page 47 of 144 Fxy (Digital) 3 B 3.2.2 B 3.2 POWER DISTRIBUTION LIMITS B 3.2.2 Planar Radial Peaking Factors (Fxy) (Digital) 3 BASES BACKGROUND The purpose of this LCO is to limit the core power distribution to the initial values assumed in the accident analyses. Operation within the limits imposed by this LCO either limits or prevents potential fuel cladding failures that could breach the primary fission product barrier and release fission products to the reactor coolant in the event of a loss of coolant accident (LOCA), loss of flow accident, ejected control element assembly (CEA) accident, or other postulated accident requiring termination by a Protective Reactor Protection System (RPS) trip function. This LCO limits damage 1 to the fuel cladding during an accident by ensuring that the plant is operating within acceptable conditions at the onset of a transient.

Methods of controlling the power distribution include:

a. Using full or part length CEAs to alter the axial power distribution,

b. Decreasing CEA insertion by boration, thereby improving the radial power distribution, and

c. Correcting off optimum conditions (e.g., a CEA drop or misoperation of the unit) that cause margin degradations.

The core power distribution is controlled so that, in conjunction with other core operating parameters (CEA insertion and alignment limits), the power distribution does not result in violation of this LCO. Limiting safety system settings and this LCO are based on the accident analyses (Refs. 1 and 2), so that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences (AOOs), and the limits of acceptable consequences are not exceeded for other postulated accidents.

Limiting power distribution skewing over time also minimizes xenon distribution skewing, which is a significant factor in controlling axial power distribution. Power distribution is a product of multiple parameters, various combinations of which may produce acceptable power distributions. Operation within the design limits of power distribution is accomplished by generating operating limits on linear heat rate (LHR) and departure from nucleate boiling (DNB).

CEOG STS San Onofre - Draft B 3.2.2-1 Revision XXX Rev. 3.0, 03/31/04 1 Attachment 1, Volume 5, Rev. 0, Page 47 of 144

Attachment 1, Volume 5, Rev. 0, Page 48 of 144 Fxy (Digital) 3 B 3.2.2 BASES BACKGROUND (continued)

Proximity to the DNB condition is expressed by the departure from nucleate boiling ratio (DNBR), defined as the ratio of the cladding surface heat flux required to cause DNB to the actual cladding surface heat flux.

The minimum DNBR value during both normal operation and AOOs is [ ] 1.31 4 as calculated by the CE-1 Correlation (Ref. 3) and corrected for such factors as rod bow and grid spacers, and it is accepted as an appropriate margin to DNB for all operating conditions.

There are two systems that monitor core power distribution online: the Core Operating Limit Supervisory System (COLSS) and the core protection calculators (CPCs). The COLSS and CPCs that monitor the core power distribution are capable of verifying that the LHR and the DNBR do not exceed their limits. The COLSS performs this function by continuously monitoring the core power distribution and calculating core power operating limits corresponding to the allowable peak LHR and DNBR values. The CPCs perform this function by continuously calculating actual values of DNBR and local power density (LPD) for comparison with the respective trip setpoints.

DNBR penalty factors are included in both the COLSS and CPC DNBR calculations to accommodate the effects of rod bow. The amount of rod bow in each assembly is dependent upon the average burnup experienced by that assembly. Fuel assemblies that incur higher than average burnup experience greater rod bow. Conversely, fuel assemblies that receive lower than average burnup experience less rod bow. In design calculations for a reload core, each batch of fuel is assigned a penalty applied to the maximum integrated planar radial power peak of the batch. This penalty is correlated with the amount of rod bow determined from the maximum average assembly burnup of the batch. A single net penalty for the COLSS and CPCs is then determined from the penalties associated with each batch that comprises a core reload, accounting for the offsetting margins due to the lower radial power peaks in the higher burnup batches.

The COLSS indicates continuously to the operator how near the core is to the operating limits and provides an audible alarm if an operating limit is exceeded. Such a condition signifies a reduction in the capability of the plant to withstand an anticipated transient, but does not necessarily imply an immediate violation of fuel design limits. If the margin to fuel design limits continues to decrease, the RPS ensures that the specified acceptable fuel design limits are not exceeded for AOOs by initiating a reactor trip.

1 CEOG STS San Onofre - Draft B 3.2.2-2 Revision XXX Rev. 3.0, 03/31/04 Attachment 1, Volume 5, Rev. 0, Page 48 of 144

Attachment 1, Volume 5, Rev. 0, Page 49 of 144 Fxy (Digital) 3 B 3.2.2 BASES BACKGROUND (continued)

The COLSS continually generates an assessment of the calculated margin for LHR and DNBR specified limits. The data required for these assessments include measured incore neutron flux, CEA positions, and Reactor Coolant System (RCS) inlet temperature, pressure, and flow.

In addition to monitoring performed by the COLSS, the RPS (via the CPCs) continually infers the core power distribution and thermal margins by processing reactor coolant data, signals from excore neutron flux detectors, and input from redundant reed switch assemblies that indicates CEA position. In this case, the CPCs assume a minimum core power of 20% RTP. This threshold is set at 20% RTP because the power range excore neutron flux detecting system is inaccurate below this power level.

If power distribution or other parameters are perturbed as a result of an AOO, the high LPD or low DNBR trips in the RPS initiate a reactor trip before fuel design limits are exceeded.

Tq The limits on ASI, Fxy, and TQ represent limits within which the LHR and 6 DNBR algorithms are valid. These limits are obtained directly from the initial core or reload analysis.

APPLICABLE The fuel cladding must not sustain damage as a result of normal SAFETY operation or AOOs (Ref. 4). The power distribution and CEA insertion ANALYSES and alignment LCOs prevent core power distributions from reaching levels that violate the following fuel design criteria:

a. During a LOCA, peak cladding temperature must not exceed 2200°F (Ref. 5),

b. During a loss of flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel rod in the core does not experience a DNB condition (Ref. 4), 1 Refs. 6 and 7

c. During an ejected CEA accident, the fission energy input to the fuel must not exceed 280 cal/gm (Ref. [ ]), and 4 Refs. 8 and 9

d. The control rods must be capable of shutting down the reactor with a minimum required SDM with the highest worth control rod stuck fully withdrawn (GDC 26, Ref. [ ]). 4 1, , 10 The power density at any point in the core must be limited to maintain the 1

fuel design criteria (Refs. 4 and 5). This result is accomplished by maintaining the power distribution and reactor coolant conditions so that the peak LHR and DNB parameters are within operating limits supported by the accident analyses (Ref. 1) with due regard for the correlations between measured quantities, the power distribution, and the uncertainties in the determination of power distribution.

CEOG STS San Onofre - Draft B 3.2.2-3 Revision XXX Rev. 3.0, 03/31/04 1 Attachment 1, Volume 5, Rev. 0, Page 49 of 144

Attachment 1, Volume 5, Rev. 0, Page 50 of 144 Fxy (Digital) 3 B 3.2.2 BASES APPLICABLE SAFETY ANALYSES (continued)

Fuel cladding failure during a LOCA is limited by restricting the maximum linear heat generation rate so that the peak cladding temperature does not exceed 2200°F (Ref. 5). Peak cladding temperatures exceeding 2200°F cause severe cladding failure by oxidation due to a Zircaloy water reaction.

The LCOs governing LHR, ASI, and RCS ensure that these criteria are met as long as the core is operated within the ASI and Fxy limits specified 6

Tq in the COLR, and within the TQ limits. The latter are process variables that characterize the three dimensional power distribution of the reactor core. Operation within the limits for these variables ensures that their actual values are within the ranges used in the accident analyses.

Fuel cladding damage does not normally occur because of conditions Tq outside the limits of these LCOs for ASI, Fxy, and TQ during normal 6 operation. However, fuel cladding damage results if an accident or AOO occurs from initial conditions outside the limits of these LCOs. This potential for fuel cladding damage exists because changes in the power distribution can cause increased power peaking and correspondingly increased LHR.

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

LCO The power distribution LCO limits are based on correlations between power peaking and certain measured variables used as inputs to the LHR and DNBR operating limits. The power distribution LCO limits are provided in the COLR.

Limiting of the calculated Planar Radial Peaking Factors ( FXY C

) used in the COLSS and CPCs to values equal to or greater than the measured Planar Radial Peaking Factors ( FXY M

) ensures that the limits calculated by the COLSS and CPCs remain valid.

APPLICABILITY Power distribution is a concern any time the reactor is critical. The power distribution LCOs, however, are only applicable in MODE 1 above 20% RTP. The reasons these LCOs are not applicable below 20% RTP are:

a. The incore neutron detectors that provide input to the COLSS, which then calculates the operating limits, are inaccurate because of the poor signal to noise ratio that they experience at relatively low core power levels and CEOG STS San Onofre - Draft B 3.2.2-4 Revision XXX Rev. 3.0, 03/31/04 1 Attachment 1, Volume 5, Rev. 0, Page 50 of 144

Attachment 1, Volume 5, Rev. 0, Page 51 of 144 Fxy (Digital) 3 B 3.2.2 BASES APPLICABILITY (continued)

b. As a result of this inaccuracy, the CPCs assume a minimum core power of 20% RTP when generating the LPD and DNBR trip signals.

When the core power is below 20% RTP, the core is operating well below its thermal limits, and the resultant CPC calculated LPD and DNBR trips are highly conservative.

ACTIONS A.1.1 and A.1.2 When the FXY M values exceed the FXY C values used in the COLSS and CPCs, nonconservative operating limits and trip setpoints may be calculated. In this case, action must be taken to ensure that the COLSS operating limits and CPC trip setpoints remain valid with respect to the accident analysis. The operator can do this by performing the Required Actions A.1.1 and A.1.2. The 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Completion Time provides the time required to calculate the required multipliers and make the necessary adjustments to the CPC addressable constants. During this period the DNBR and LHR setpoints may be slightly nonconservative but DNBR and LHR are still within limits. Therefore, 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is an acceptable Completion Time to perform these actions considering the low probability of an accident occurring during this time period.

A.2 As an alternative to Required Actions A.1.1 and A.1.2, the operator may adjust the affected values of FXY C used in the COLSS and CPCs to values FXY . The 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Completion Time provides the time required to M

calculate the required multipliers and make the necessary adjustments to the CPC addressable constants. During this period the DNBR and LHR setpoints may be slightly nonconservative but DNBR and LHR are still within limits. Therefore, 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is an acceptable Completion Time to perform these actions considering the low probability of an accident occurring during this time period.

CEOG STS San Onofre - Draft B 3.2.2-5 Revision XXX Rev. 3.0, 03/31/04 1 Attachment 1, Volume 5, Rev. 0, Page 51 of 144

Attachment 1, Volume 5, Rev. 0, Page 52 of 144 3

Fxy (Digital)

B 3.2.2 BASES ACTIONS (continued)

A.3 If Required Actions A.1.1 and A.1.2 or A.2 cannot be accomplished within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , the core power must be reduced. Reduction to 20% RTP or less ensures that the core is operating within the specified thermal limits and places the core in a conservative condition based on the trip setpoints generated by the COLSS and CPC operating limits; these limits are established assuming a minimum core power of 20% RTP. Six hours is a reasonable time to reach 20% RTP in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.2.2.1 REQUIREMENTS This periodic Surveillance is for determining, using the Incore Detector System, that FXY M values are FXY C values used in the COLSS and CPCs.

It ensures that the FXY values used remain valid throughout the fuel cycle.

C A Frequency of 31 EFPD is acceptable because the power distribution TSTF-INSERT 1 changes only slightly with the amount of fuel burnup. Determining the FXY M 425-A values after each fuel loading when THERMAL POWER is > 40% RTP, but prior to its exceeding 70% RTP, ensures that the core is properly loaded. 85 REFERENCES 1. FSAR, Section [15].

1 4 U Chapter

2. FSAR, Section [6].

3. CE-1 Correlation for DNBR.

4. 10 CFR 50.46, Appendix A, GDC 10. 2

5. 10 CFR 50.46. 1

6. UFSAR, Section 4.4.1.1.

7. UFSAR, Table 15.0-8.

8. UFSAR, Section 15.4.3.2.

9. UFSAR, Section 15.10. 4.3.2.

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

CEOG STS San Onofre - Draft B 3.2.2-6 Revision XXX Rev. 3.0, 03/31/04 1 Attachment 1, Volume 5, Rev. 0, Page 52 of 144

Attachment 1, Volume 5, Rev. 0, Page 53 of 144 B 3.2.2 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 should utilize the appropriate Frequency description, given above, and the appropriate choice of 5 Frequency in the Surveillance Requirement.

Insert Page B 3.2.2-6 Attachment 1, Volume 5, Rev. 0, Page 53 of 144

Attachment 1, Volume 5, Rev. 0, Page 54 of 144 JUSTIFICATION FOR DEVIATIONS ITS 3.2.2 BASES, PLANAR RADIAL PEAKING FACTORS (Fxy)

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 reference to 10 CFR 50.46 Appendix A, GDC 10 is being corrected to 10 CFR 50 Appendix A, GDC 10. The GDC's are located in 10 CFR 50 Appendix A and 10 CFR 50.46 does not contain an Appendix A.

3. The headings for ISTS 3.2.2 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.

4. The ISTS Bases 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 changed to reflect the current licensing basis.

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 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.

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 are not always true for each of the Frequencies.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 5, Rev. 0, Page 54 of 144

Attachment 1, Volume 5, Rev. 0, Page 55 of 144 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 5, Rev. 0, Page 55 of 144

Attachment 1, Volume 5, Rev. 0, Page 56 of 144 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.2, PLANAR RADIAL PEAKING FACTORS (Fxy)

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

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 5, Rev. 0, Page 56 of 144

, Volume 5, Rev. 0, Page 57 of 144 ATTACHMENT 3 ITS 3.2.3, AZIMUTHAL POWER TILT (Tq) , Volume 5, Rev. 0, Page 57 of 144

, Volume 5, Rev. 0, Page 58 of 144 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 5, Rev. 0, Page 58 of 144

Attachment 1, Volume 5, Rev. 0, Page 59 of 144 Tq ITS A01 3.2.3 3.2 POWER DISTRIBUTION LIMITS 3.2.3 3.2.3 AZIMUTHAL POWER TILT (T q)

LCO 3.2.3 LCO 3.2.3 The measured T q shall be less than or equal to the T q allowance used in the core protection calculators (CPCs).

Applicability APPLICABILITY: MODE 1 with THERMAL POWER > 20% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. Measured T q greater A.1 Restore measured T q 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months than the allowance to less than or equal used in the CPCs. to the allowance used in the CPCs. A02 and < 0.10 OR A.2 Adjust the T q 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months allowance in the CPCs to greater than or equal to the measured T q.

(continued)

SAN ONOFRE--UNIT 2 3.2-5 Amendment No. 127 Attachment 1, Volume 5, Rev. 0, Page 59 of 144

Attachment 1, Volume 5, Rev. 0, Page 60 of 144 ITS Tq A01 3.2.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Measured T q > 0.03 and B.1 Adjust the T q 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months

0.10. allowance in the CPCs to greater than or equal to the measured T q.

AND A02 B.2 Evaluate core design 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and safety analysis and determine that the core is acceptable for continued operation.

AND B.3 Establish appropriate 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months operating restrictions and SRs.

(continued)

SAN ONOFRE--UNIT 2 3.2-6 Amendment No. 127 Attachment 1, Volume 5, Rev. 0, Page 60 of 144

Attachment 1, Volume 5, Rev. 0, Page 61 of 144 ITS Tq A01 3.2.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION B C. Measured T q > 0.10. ------------NOTE-------------

Action C.5 must be completed M01 if power reduction commences B prior to restoring T q to

0.10.

If T q is > 0.10 due to a reason other -----------------------------

than a dropped C E A , all subsequent R equired A ctions m ust be com pleted if C.1 Adjust the T q 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months power reduction com m ences prior to allowance in the CPCs L01 restoring T q to < 0.10. If T q is > 0.10 to greater than or due to a dropped C E A , R equired equal to the measured A ction B .3 m ust be com pleted if power T q.

reduction com m ences prior to B .1 restoring T q to < 0.10. AND C.2 Reduce THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to # 50% RTP.

AND B .2 C.3 Reduce Linear Power 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Level High trip B.3 R estore the m easured T q to B.3 Completion Time setpoints to less than the T q allowance P rior to increasing T H E R M A L

55% RTP.

used in the C P C s . POW ER.

AND of the out of lim it condition C.4 Correct the cause for Prior to measured T q > 0.10. increasing A03 THERMAL POWER verified AND > 50%

m ay proceed provided that the C.5 Verify measured T q is Subsequent to

0.10 at least once power operation per hour for 12 > 50% RTP C om pletion T im e N O T E hours, or until verified at

$ 95% RTP.

ACTION C D. Required Actions and D.1 Reduce THERMAL POWER 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion to # 20%.

Times not met.

C . C .1 SAN ONOFRE--UNIT 2 3.2-7 Amendment No. 127 Attachment 1, Volume 5, Rev. 0, Page 61 of 144

Attachment 1, Volume 5, Rev. 0, Page 62 of 144 ITS Tq A01 3.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY required to be met A04 SR 3.2.3.1 SR 3.2.3.1 -------------------NOTES-------------------

In accordance with Only applicable when COLSS is out of the S urveillance service. With COLSS in service, this LA01 Frequency C ontrol parameter is continuously monitored.

P rogram Calculate T q and verify it is less than or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months equal to the T q allowance used in the CPCs.

SR 3.2.3.2 SR 3.2.3.2 Verify COLSS azimuthal tilt alarm is 31 days actuated at a T q value less than or equal to the T q value used in the CPCs.

SR 3.2.3.3 SR 3.2.3.3 Independently confirm the validity of the 31 EFPD COLSS calculated T q by use of the incore detectors.

SAN ONOFRE--UNIT 2 3.2-8 Amendment No. 127 Attachment 1, Volume 5, Rev. 0, Page 62 of 144

Attachment 1, Volume 5, Rev. 0, Page 63 of 144 Tq ITS A01 3.2.3 3.2 POWER DISTRIBUTION LIMITS 3.2.3 3.2.3 AZIMUTHAL POWER TILT (T q)

LCO 3.2.3 LCO 3.2.3 The measured T q shall be less than or equal to the T q allowance used in the core protection calculators (CPCs).

Applicability APPLICABILITY: MODE 1 with THERMAL POWER > 20% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. Measured T q greater A.1 Restore measured T q 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months than the allowance to less than or equal used in the CPCs. to the allowance used in the CPCs. A02 and < 0.10 OR A.2 Adjust the T q 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months allowance in the CPCs to greater than or equal to the measured T q.

(continued)

SAN ONOFRE--UNIT 3 3.2-5 Amendment No. 116 Attachment 1, Volume 5, Rev. 0, Page 63 of 144

Attachment 1, Volume 5, Rev. 0, Page 64 of 144 ITS Tq A01 3.2.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Measured T q > 0.03 and B.1 Adjust the T q 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months

0.10. allowance in the CPCs to greater than or equal to the measured T q.

AND A02 B.2 Evaluate core design 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and safety analysis and determine that the core is acceptable for continued operation.

AND B.3 Establish appropriate 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months operating restrictions and SRs.

(continued)

SAN ONOFRE--UNIT 3 3.2-6 Amendment No. 116 Attachment 1, Volume 5, Rev. 0, Page 64 of 144

Attachment 1, Volume 5, Rev. 0, Page 65 of 144 ITS Tq A01 3.2.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION B C. Measured T q > 0.10. ------------NOTE-------------

Action C.5 must be completed M01 if power reduction commences B prior to restoring T q to

0.10.

If T q is > 0.10 due to a reason other -----------------------------

than a dropped C E A , all subsequent R equired A ctions m ust be com pleted if C.1 Adjust the T q 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months power reduction com m ences prior to allowance in the CPCs L01 restoring T q to < 0.10. If T q is > 0.10 to greater than or due to a dropped C E A , R equired equal to the measured A ction B .3 m ust be com pleted if power T q.

reduction com m ences prior to B .1 restoring T q to < 0.10. AND C.2 Reduce THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to # 50% RTP.

AND B .2 C.3 Reduce Linear Power 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Level High trip B.3 R estore the m easured T q to B.3 Completion Time setpoints to less than the T q allowance P rior to increasing T H E R M A L

55% RTP.

used in the C P C s . POW ER.

AND of the out of lim it condition C.4 Correct the cause for Prior to measured T q > 0.10. increasing A03 THERMAL POWER verified AND > 50%

m ay proceed provided that the C.5 Verify measured T q is Subsequent to

0.10 at least once power operation per hour for 12 > 50% RTP C om pletion T im e N O T E hours, or until verified at

$ 95% RTP.

ACTION C D. Required Actions and D.1 Reduce THERMAL POWER 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion to # 20%.

Times not met.

C . C .1 SAN ONOFRE--UNIT 3 3.2-7 Amendment No. 116 Attachment 1, Volume 5, Rev. 0, Page 65 of 144

Attachment 1, Volume 5, Rev. 0, Page 66 of 144 ITS Tq A01 3.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY required to be met A04 SR 3.2.3.1 SR 3.2.3.1 -------------------NOTES-------------------

In accordance with Only applicable when COLSS is out of the S urveillance service. With COLSS in service, this LA01 Frequency C ontrol parameter is continuously monitored.

P rogram Calculate T q and verify it is less than or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months equal to the T q allowance used in the CPCs.

SR 3.2.3.2 SR 3.2.3.2 Verify COLSS azimuthal tilt alarm is 31 days actuated at a T q value less than or equal to the T q value used in the CPCs.

SR 3.2.3.3 SR 3.2.3.3 Independently confirm the validity of the 31 EFPD COLSS calculated T q by use of the incore detectors.

SAN ONOFRE--UNIT 3 3.2-8 Amendment No. 116 Attachment 1, Volume 5, Rev. 0, Page 66 of 144

Attachment 1, Volume 5, Rev. 0, Page 67 of 144 DISCUSSION OF CHANGES ITS 3.2.3, AZIMUTHAL POWER TILT (Tq)

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 3.2.3 ACTION B is for the Condition when measured Tq is greater than 0.03 and less than or equal to 0.10. When in this Condition, CTS requires the adjustment of the Tq allowance (Required Action B.1), evaluation of the core design and safety analysis and a determination that the core is acceptable for continued operations (Required Action B.2), and establishment of appropriate operating restrictions and SRs (Required Action B.3). ITS 3.2.3 does not contain a similar ACTION as CTS 3.2.3 ACTION B, but consolidates the CTS 3.2.3 ACTIONS A and B into ITS 3.2.3 ACTION A. Furthermore, the ITS does not require an evaluation of core design and safety analysis and a determination that core design is acceptable for continued operation and an establishment of appropriate restrictions and SRs. This changes the CTS by consolidating the two CTS ACTIONS into a single ITS ACTION, and deletes the CTS Required Actions B.2 and B.3.

CTS 3.2.3 ACTION B is for the condition when the measured Tq > 0.03 and 0.10. ITS 3.2.3 incorporates this CTS ACTION into ITS 3.2.3 ACTION A. The deletion of Required Action B.2 and B.3 is acceptable because if the Required Actions (either ITS 3.2.3 Required Action A.1 or A.2) are accomplished within the Completion Times, both the Core Design and Safety Analysis are maintained within the Design Basis. If the Required Actions are not completed within the required Completion Times, ITS 3.2.3 ACTION C is required to be entered and the unit will be required to reduce power and exit the Applicability of the LCO.

This will ensure the plant takes appropriate steps to ensuring an evaluation is performed before plant restart. This change is considered administrative because the TS was only reorganized to be more efficient. The intent and action taken when the LCO is not met or the Required Actions cannot be performed within the Completion Times have not been altered. This change is consistent with NUREG-1432.

A03 CTS 3.2.3 Required Actions C.4 and C.5 require the cause for the measured Tq >

0.10 to be corrected prior to increasing THERMAL POWER > 50% (Required Action C.4) and to verify, subsequent to power operation > 50% RTP, measured Tq is < 0.10 at least once per hour for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , or until verified at > 95% RTP (Required Action C.5). ITS 3.2.3 Required Action B.3 requires the restoration of the measured Tq to less than the Tq allowance used in the CPCs prior to increasing THERMAL POWER. The prior to increasing THERMAL POWER Completion Time is modified by a Note that states to correct the cause of the out of limit condition prior to increasing THERMAL POWER and that subsequent San Onofre Unit 2 and 3 Page 1 of 6 Attachment 1, Volume 5, Rev. 0, Page 67 of 144

Attachment 1, Volume 5, Rev. 0, Page 68 of 144 DISCUSSION OF CHANGES ITS 3.2.3, AZIMUTHAL POWER TILT (Tq) power operation > 50% RTP may proceed provided that the measured Tq is verified < 0.10 at least once per hour for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , or until verified at > 95% RTP.

This changes the CTS by clearly stating in a Required Action to restore the Tq prior to increasing THERMAL POWER, and including all the amplifying information concerning the periodic verification of measured Tq to a Note for the Completion Time.

This change is only a clarification of the current requirement. This change does not affect the technical requirements, and is made to be consistent with the current wording of NUREG-1432. The proposed wording makes it clear that the requirement is to restore the Tq to within its limit. This change is designated administrative because it does not result in any technical changes to the CTS requirements.

A04 CTS SR 3.2.3.1 contains a Note which modifies the SR by making it only "applicable" when COLSS is out of service. ITS SR 3.2.3.1 revises the Note to be only "required to be met" when COLSS is out of service. This changes the CTS by clarifying what applicable means (i.e., not required to be met) based on the changes to Section 1.4.

TSTF-284 revised CTS Section 1.4 to add a discussion regarding the use of "met" and "perform" in SR Notes and adds examples to facilitate the use and application of SR Notes that utilize "met" and "perform." The TSTF also revises SR Notes, as necessary to appropriately clarify the use of "met" and "perform" exceptions. The SONGS CTS do not contain this detail; however, various locations throughout the TS provide Notes with "met" and "performed" distinctions. This change does not change the intent of any SR Note. This proposed change will provide for better use, application, and understanding of this Note along with the changes to Section 1.4. This is an administrative change which clarifies and corrects exceptions that are unclear or have incorrect usage of "met" and "perform" MORE RESTRICTIVE CHANGES M01 The CTS 3.2.3 ACTION C Required Actions are modified by a Note that states Required Action C.5 must be completed if power reduction commences prior to restoring Tq to < 0.10. This CTS Required Action requires a verification, prior to exceeding 50% RTP, that measured Tq is < 0.10 at least once per hour for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , or until verified at > 95% RTP. ITS 3.2.3 ACTION B Required Actions are modified by a Note that states if Tq is > 0.10 due to a reason other than a dropped CEA, all subsequent Required Actions must be completed if power reduction commences prior to restoring Tq to < 0.10. Furthermore, the Note states that if Tq is > 0.10 due to a dropped CEA, Required Action B.3 must be completed if power reduction commences prior to restoring Tq to < 0.10. This changes the CTS by requiring all of the Required Actions to be completed, not just the Tq verification if Tq is > 0.10 due to a reason other than a dropped CEA.

The purpose of the ITS 3.2.3 Note is to ensure corrective action is taken before unrestricted power operation resumes. The Note will ensure that if Tq is > 0.10 due to reasons other than a dropped CEA, then in addition to the Tq verification, San Onofre Unit 2 and 3 Page 2 of 6 Attachment 1, Volume 5, Rev. 0, Page 68 of 144

Attachment 1, Volume 5, Rev. 0, Page 69 of 144 DISCUSSION OF CHANGES ITS 3.2.3, AZIMUTHAL POWER TILT (Tq)

THERMAL POWER is reduced to < 50% RTP and the Linear Power Level - High trip setpoints are reduced to < 55% RTP. This change is acceptable because it requires performance of all the Required Actions in lieu of only one of the Required Actions, prior to increasing power above 50% RTP, if Tq is > 0.10 due to a reason other than a dropped CEA. This change is designated as more restrictive because more Required Actions must be performed in the ITS than in the CTS.

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 3.2.3 contains three SRs. CTS SR 3.2.3.1 requires Tq to be calculated and verified it is less than or equal to the Tq allowance used in CPCs every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . CTS SR 3.2.3.2 requires the verification COLSS azimuthal tilt alarm is actuated at a Tq value less than or equal to the Tq value used in the CPCs every 31 days. CTS SR 3.2.3.3 requires the validity of the COLSS calculated Tq to be independently confirmed by use of incore detectors every 31 EFPD. ITS SR 3.2.3.1, SR 3.2.3.2, and SR 3.2.3.3 are 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 SRs and the Bases for the Frequencies 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 San Onofre Unit 2 and 3 Page 3 of 6 Attachment 1, Volume 5, Rev. 0, Page 69 of 144

Attachment 1, Volume 5, Rev. 0, Page 70 of 144 DISCUSSION OF CHANGES ITS 3.2.3, AZIMUTHAL POWER TILT (Tq)

Frequency. NEI 04-10, Rev. 1, has been reviewed and approved by the NRC.