Text

Attachment 1, Volume 10, San Onofre Nuclear Generating Station - Improved Technical Specifications Conversion - ITS Section 3.7, Plant Systems
	ML11251A103
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: ML11251A103 (485)
	v • d • e

Attachment 1, Volume 10, Rev. 0, Page 1 of 485 ATTACHMENT 1 VOLUME 10 SAN ONOFRE NUCLEAR GENERATING STATION IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.7 PLANT SYSTEMS Attachment 1, Volume 10, Rev. 0, Page 1 of 485

Attachment 1, Volume 10, Rev. 0, Page 2 of 485 LIST OF ATTACHMENTS

1. ITS 3.7.1 - MAIN STEAM SAFETY VALVES

2. ITS 3.7.2 - MAIN STEAM ISOLATION VALVES

3. ITS 3.7.3 - MAIN FEEDWATER ISOLATION VALVES

4. ITS 3.7.4 - ATMOSPHERIC DUMP VALVES

5. ITS 3.7.5 - AUXILIARY FEEDWATER SYSTEM

6. ITS 3.7.6 - CONDENSATE STORAGE TANKS

7. ITS 3.7.7 - COMPONENT COOLING WATER SYSTEM

8. ITS 3.7.8 - SALT WATER COOLING SYSTEM

9. ITS 3.7.10 - EMERGENCY CHILLED WATER

10. ITS 3.7.11 - CONTROL ROOM EMERGENCY AIR CLEANUP SYSTEM

11. ITS 3.7.12 - CONTROL ROOM EMERGENCY AIR TEMPERATURE CONTROL SYSTEM

12. ITS 3.7.16 - FUEL STORAGE POOL WATER LEVEL

13. ITS 3.7.17 - FUEL STORAGE POOL BORON CONCENTRATION

14. ITS 3.7.18 - SPENT FUEL ASSEMBLY STORAGE

15. ITS 3.7.19 - SECONDARY SPECIFIC ACTIVITY

16. ISTS SPECIFICATIONS NOT USED NOTE: There is no ITS 3.7.9, 3.7.13, 3.7.14, or 3.7.15 Attachment 1, Volume 10, Rev. 0, Page 2 of 485

, Volume 10, Rev. 0, Page 3 of 485 ATTACHMENT 1 ITS 3.7.1, MAIN STEAM SAFETY VALVES , Volume 10, Rev. 0, Page 3 of 485

, Volume 10, Rev. 0, Page 4 of 485 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 10, Rev. 0, Page 4 of 485

Attachment 1, Volume 10, Rev. 0, Page 5 of 485 ITS MSSVs A01 3.7.1 3.7 PLANT SYSTEMS 3.7.1 Main Steam Safety Valves (MSSVs)

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

Applicability APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

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

ACTIONS Separate Condition entry is allowed for each MSSV.

Note CONDITION REQUIRED ACTION COMPLETION TIME One or more ACTION A A. Two to seven required A.1 Reduce power to less 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months A02 MSSVs per SG than or equal to the inoperable. applicable % RTP listed in Table 3.7.1-1.

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

ACTION B B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND steam generators OR with less than two B.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months One Eight or more required A02 MSSVs per SG inoperaple.

OPERABLE SAN ONOFRE--UNIT 2 3.7-1 Amendment No. 212 Attachment 1, Volume 10, Rev. 0, Page 5 of 485

Attachment 1, Volume 10, Rev. 0, Page 6 of 485 ITS MSSVs A01 3.7.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 SR 3.7.1.1 -------------------NOTE--------------------

Only required to be performed in MODES 1 and 2.

Verify each required MSSV lift setpoint In accordance within limits per Table 3.7.1-2 in with the accordance with the Inservice Testing Inservice Program. Testing Program A03 Following testing, lift settings shall be within + 1%.

SAN ONOFRE--UNIT 2 3.7-2 Amendment No. 127 Attachment 1, Volume 10, Rev. 0, Page 6 of 485

Attachment 1, Volume 10, Rev. 0, Page 7 of 485 ITS MSSVs A01 A02 3.7.1 Table 3.7.1-1 Table 3.7.1-1 (page 1 of 1)

Maximum Allowable Power Level and Linear Power Level - High Trip Setpoint versus Inoperable MSSVs OPERABLE Main Steam Safety Valves MAXIMUM MINIMUM ALLOWABLE MAXIMUM NUMBER OF INOPERABLE LINEAR POWER ALLOWABLE POWER MSSVs PER STEAM GENERATOR LEVEL HIGH TRIP

(% RTP)

REQUIRED OPERABLE - (% RTP) SETPOINT 2 8 95 95 7

100 111 6 3 56 56 5 4 46 46 5 to 7 MODE 3 Not applicable 4 0 (i.e., )

0 (i.e., MODE 3) 3 NA 0 (i.e., MODE 3) 2 NA NA SAN ONOFRE--UNIT 2 3.7-3 Amendment No. 212 Attachment 1, Volume 10, Rev. 0, Page 7 of 485

Attachment 1, Volume 10, Rev. 0, Page 8 of 485 ITS MSSVs A01 3.7.1 Table 3.7.1-2 Table 3.7.1-2 (page 1 of 1)

Main Steam Safety Valves (Lift Settings)

VALVE NUMBER LIFT SETTING*

Steam Steam (psig)

Generator Generator

1 #2 2PSV-8401 2PSV-8410 1085 2PSV-8402 2PSV-8411 1092 A04 2PSV-8403 2PSV-8412 1099 2PSV-8404 2PSV-8413 1106 2PSV-8405 2PSV-8414 1113 2PSV-8406 2PSV-8415 1120 2PSV-8407 2PSV-8416 1127 2PSV-8408 2PSV-8417 1134 2PSV-8409 2PSV-8418 1140 The lift setting pressure shall correspond to ambient conditions of the LA01 valve at nominal operating temperature and pressure. Each MSSV has an as-found tolerance of +2%/-3%. Following testing according to Technical Specification 5.5.2.10, MSSVs will be set within +/-1% of the specified A03 SR 3.7.1.1 lift setpoint. lift setting shall SAN ONOFRE--UNIT 2 3.7-4 Amendment No. 212 Attachment 1, Volume 10, Rev. 0, Page 8 of 485

Attachment 1, Volume 10, Rev. 0, Page 9 of 485 ITS MSSVs A01 3.7.1 3.7 PLANT SYSTEMS 3.7.1 Main Steam Safety Valves (MSSVs)

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

Applicability APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

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

ACTIONS Separate Condition entry is allowed for each MSSV.

Note CONDITION REQUIRED ACTION COMPLETION TIME One or more ACTION A A. Two to seven required A.1 Reduce power to less 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months A02 MSSVs per SG than or equal to the inoperable. applicable % RTP listed in Table 3.7.1-1.

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

ACTION B B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND steam generators OR with less than two B.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months One Eight or more required A02 MSSVs per SG inoperaple.

OPERABLE SAN ONOFRE--UNIT 3 3.7-1 Amendment No. 204 Attachment 1, Volume 10, Rev. 0, Page 9 of 485

Attachment 1, Volume 10, Rev. 0, Page 10 of 485 ITS MSSVs A01 3.7.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 SR 3.7.1.1 -------------------NOTE--------------------

Only required to be performed in MODES 1 and 2.

Verify each required MSSV lift setpoint In accordance within limits per Table 3.7.1-2 in with the accordance with the Inservice Testing Inservice Program. Testing Program A03 Following testing, lift settings shall be within + 1%.

SAN ONOFRE--UNIT 3 3.7-2 Amendment No. 116 Attachment 1, Volume 10, Rev. 0, Page 10 of 485

Attachment 1, Volume 10, Rev. 0, Page 11 of 485 ITS MSSVs A01 A02 3.7.1 Table 3.7.1-1 Table 3.7.1-1 (page 1 of 1)

Maximum Allowable Power Level and Linear Power Level - High Trip Setpoint versus Inoperable MSSVs OPERABLE Main Steam Safety Valves MAXIMUM MINIMUM ALLOWABLE MAXIMUM NUMBER OF INOPERABLE LINEAR POWER ALLOWABLE POWER MSSVs PER STEAM GENERATOR LEVEL HIGH TRIP

(% RTP)

REQUIRED OPERABLE - (% RTP) SETPOINT 2 8 95 95 7

100 111 6 3 56 56 5 4 46 46 5 to 7 MODE 3 Not applicable 4 0 (i.e., )

3 0 (i.e., MODE 3)

NA 2 0 (i.e., MODE 3)

NA NA SAN ONOFRE--UNIT 3 3.7-3 Amendment No. 204 Attachment 1, Volume 10, Rev. 0, Page 11 of 485

Attachment 1, Volume 10, Rev. 0, Page 12 of 485 ITS MSSVs A01 3.7.1 Table 3.7.1-2 Table 3.7.1-2 (page 1 of 1)

Main Steam Safety Valves (Lift Settings)

VALVE NUMBER LIFT SETTING*

Steam Generator Steam Generator (psig)

1 #2 3PSV-8401 3PSV-8410 1085 A04 3PSV-8402 3PSV-8411 1092 3PSV-8403 3PSV-8412 1099 3PSV-8404 3PSV-8413 1106 3PSV-8405 3PSV-8414 1113 3PSV-8406 3PSV-8415 1120 3PSV-8407 3PSV-8416 1127 3PSV-8408 3PSV-8417 1134 3PSV-8409 3PSV-8418 1140

The lift setting pressure shall correspond to ambient conditions of the LA01 valve at nominal operating temperature and pressure. Each MSSV has an as-found tolerance of +2%/-3%. Following testing according to Technical Specification 5.5.2.10, MSSVs will be set within +/-1% of the specified A03 SR 3.7.1.1 lift setpoint. lift setting shall SAN ONOFRE--UNIT 3 3.7-4 Amendment No. 204 Attachment 1, Volume 10, Rev. 0, Page 12 of 485

Attachment 1, Volume 10, Rev. 0, Page 13 of 485 DISCUSSION OF CHANGES ITS 3.7.1, MAIN STEAM SAFETY VALVES 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 3.7.1 Condition A is for the condition when two to seven required MSSVs per SG are inoperable. The second condition in CTS 3.7.1 Condition B is for the condition when eight or more required MSSVs per SG are inoperable. CTS Table 3.7.1-1 contains the maximum allowable Linear Power Level High trip and maximum allowable power for a corresponding number of inoperable MSSVs per Steam Generator (SG). The Table only provides values when 2 or more MSSV's are inoperable. No actions are required when one MSSV is inoperable.

ITS 3.7.1 ACTION A is for the Condition when one or more required MSSVs are inoperable and the second condition in Condition B is for the condition when one or more steam generators with less than two MSSVs that are OPERABLE. ITS Table 3.7.1-1 contains the maximum allowable Linear Power Level - High Trip Setpoint and the maximum power for a corresponding minimum number of MSSVs per SG required OPERABLE. This changes the CTS wording of Condition A, the second condition of Condition B, and Table 3.7.1-1. This also changes the CTS by providing the maximum power and trip setpoint when all required MSSVs per SG are OPERABLE (i.e., when 8 are OPERABLE).

The CTS 3.7.1 wording in Condition A, the second condition of Condition B, and Table 3.7.1-1 are being changed to be consistent with the wording in the ISTS without changing how the Condition or Table is applied. The major change in wording to note is that the Table will now list the minimum number of MSSVs per SG required to be OPERABLE versus the Number of Inoperable MSSVs per SG; however the corresponding maximum power allowed and the Linear Power Level

- High Trip Setpoint requirements are not being changed. Specifically, SONGS Units 2 and 3 have nine MSSVs per SG. CTS Table 3.7.1-1 only provides limits when two of the MSSVs per SG are inoperable, and CTS 3.7.1 Condition A is entered when two MSSVs per SG are inoperable. Thus, no power reduction is required until 2 of the 9 MSSVs per SG are inoperable. ITS Table 3.7.1-1 specifies that 8 MSSVs per SG are the minimum required to be OPERABLE; however, the maximum specified power level in this condition is 100% RTP.

Power reduction is only required when there are 7 MSSVs OPERABLE.

ITS 3.7.1 Condition A also states that it is entered when one or more required MSSVs are inoperable; thus it is entered when there are less than 8 OPERABLE MSSVs per SG (i.e., 2 or more total MSSVs are inoperable). ITS Table 3.7.1-1 specifies when the minimum number of MSSVs is between 4 and 2, the maximum power is 0% which is MODE 3. This is consistent with the CTS requirements. Condition B is for the case when there are less than two MSSVs OPERABLE per steam generator. This is also consistent with the CTS.

San Onofre Unit 2 and 3 Page 1 of 3 Attachment 1, Volume 10, Rev. 0, Page 13 of 485

Attachment 1, Volume 10, Rev. 0, Page 14 of 485 DISCUSSION OF CHANGES ITS 3.7.1, MAIN STEAM SAFETY VALVES Therefore, this change does not affect the actions taken when MSSVs are inoperable and is only an editorial change to be consistent with the ISTS wording preference. This change is designated as Administrative because wording is being changed without altering the application of the CTS.

A03 CTS SR 3.7.1.1 requires verification that each required MSSV lift setpoint is within limits per Table 3.7.1-2 in accordance with the Inservice Testing Program.

CTS Table 3.7.1-2 contains a footnote for the lift settings column that requires lift settings to be set, following testing per CTS 5.5.2.10, the IST Program, within +/-

1% of the values listed in the table. ITS Table 3.7.1-2 does not contain a similar footnote. However, ITS SR 3.7.1.1 requires verification that each required MSSV lift setpoint is per the values in Table 3.7.1-2 in accordance with the Inservice Testing Program and requires that following testing, the lift settings shall be within +/- 1% of the lift setting values listed in the table. This changes the CTS by moving the requirement for the lift settings to be set within +/- 1% of the lift setting values in the table from a footnote in CTS Table 3.7.1-2 to ITS SR 3.7.1.1. In addition, the portion of the footnote which references Specification 5.5.2.10 is being deleted.

This change moves the requirement for the lift setting to be set within +/- 1% from CTS Table 3.7.1-2 to ITS SR 3.7.1.1 and deletes the reference to Specification 5.5.2.10. This change is acceptable because the location of the lift setting as left tolerance requirements is more appropriate for the SR. In addition the reference to Specification 5.5.2.10 (Inservice Testing Program) is not required to ensure the requirement is met. The requirement that the lift setting be within +/- 1% is included in SR 3.7.1.1 and will continue to be required by the IST program. This change does not change the performance of the SR, but more clearly identifies the SR requirements. This change is designated as administrative because this change more clearly identifies the requirement without altering the Surveillance.

A04 CTS Table 3.7.1-2 provides the MSSV valve numbers and lift settings. ITS Table 3.7.1-2 includes the same information, except the unit designators for the valve numbers are not included. This changes the CTS by deleting the unit designator from each of the MSSV valve numbers.

The purpose of CTS Table 3.7.1-2 is to provide the lift setting for each MSSV.

The unit designators are being deleted since SONGS will have a common Technical Specification once this amendment is approved. The valve numbers and the associated lift settings for each valve are the same for the two units.

Therefore, unit designators are not necessary to identify differences between the two units, and this information has been deleted from the Technical Specifications. This change is designated as administrative because the change does not technically alter the Specifications.

MORE RESTRICTIVE CHANGES None San Onofre Unit 2 and 3 Page 2 of 3 Attachment 1, Volume 10, Rev. 0, Page 14 of 485

Attachment 1, Volume 10, Rev. 0, Page 15 of 485 DISCUSSION OF CHANGES ITS 3.7.1, MAIN STEAM SAFETY VALVES RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS Table 3.7.1-2 contains a footnote for the Lift Settings Column which in part states the lift setting pressure shall correspond to ambient conditions of the valve at nominal operating temperature and pressure.

ITS Table 3.7.1-2 does not contain this footnote. This changes the CTS by moving this detail to the Bases.

The removal of these details for performing Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS 3.7.1 still retains a requirement for the valves to be OPERABLE. Under the definition of OPERABILITY, the MSSVs must be capable of lifting at the assumed conditions, which includes the ambient operating conditions of the MSSVs themselves. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural details for meeting Technical Specification requirements are being moved from the Technical Specifications to the ITS Bases.

LESS RESTRICTIVE CHANGES None San Onofre Unit 2 and 3 Page 3 of 3 Attachment 1, Volume 10, Rev. 0, Page 15 of 485

Attachment 1, Volume 10, Rev. 0, Page 16 of 485 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 10, Rev. 0, Page 16 of 485

Attachment 1, Volume 10, Rev. 0, Page 17 of 485 U2/U3 CTS MSSVs 3.7.1 3.7 PLANT SYSTEMS 3.7.1 Main Steam Safety Valves (MSSVs)

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

Applicability APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

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

ACTIONS Separate Condition entry is allowed for each MSSV.

Note CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One or more required A.1 Reduce power to less than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months MSSVs inoperable. or equal to the applicable

% RTP listed in Table 3.7.1-1.

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

ACTION B B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND OR B.2 Be in MODE 4. [12] hours 2 One or more steam generators with less 2

than [two] MSSVs OPERABLE.

CEOG STS 3.7.1-1 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Amendment XXX Attachment 1, Volume 10, Rev. 0, Page 17 of 485

Attachment 1, Volume 10, Rev. 0, Page 18 of 485 U2/U3 CTS MSSVs 3.7.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1, SR 3.7.1.1 -------------------------------NOTE------------------------------

Table 3.7.1-2 footnote

Only required to be performed in MODES 1 and 2.

Verify each required MSSV lift setpoint per In accordance Table 3.7.1-2 in accordance with the Inservice with the Inservice Testing Program. Following testing, lift settings Testing Program shall be within + 1%.

CEOG STS 3.7.1-2 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Amendment XXX Attachment 1, Volume 10, Rev. 0, Page 18 of 485

Attachment 1, Volume 10, Rev. 0, Page 19 of 485 U2/U3 CTS MSSVs 3.7.1 Maximum Power Table 3.7.1-1 Level and Linear Table 3.7.1-1 (page 1 of 1)

Power Level- High

[Variable Overpower Trip] Setpoint versus 2 OPERABLE Main Steam Safety Valves LINEAR POWER LEVEL - HIGH MINIMUM NUMBER OF MSSVs PER STEAM MAXIMUM ALLOWABLE GENERATOR [VARIABLE OVERPOWER 2

REQUIRED OPERABLE MAXIMUM POWER TRIP] SETPOINT

(% RTP) ([CEILING] % RTP)

[8] [ ] 100 [ ] 111

[7] [ ] 95 [ ] 95

[6] [ ] 56 [ ] 56

[5] [ ] 46 [ ] 46 2

[4] [ ] 0 (i.e., MODE 3) [ ] NA

[3] [ ] 0 (i.e., MODE 3) [ ] NA

[2] [ ] 0 (i.e., MODE 3) [ ] NA CEOG STS 3.7.1-3 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Amendment XXX Attachment 1, Volume 10, Rev. 0, Page 19 of 485

Attachment 1, Volume 10, Rev. 0, Page 20 of 485 U2/U3 CTS MSSVs 3.7.1 Table 3.7.1-2 Table 3.7.1-2 (page 1 of 1)

Main Steam Safety Valve Lift Settings VALVE NUMBER LIFT SETTING Steam Generator #1 Steam Generator #2 (psig +/- [3]%) 1

+ 2% / -

[ ] [ ] [ ]

2

[ ] [ ] [ ]

INSERT 1

[ ] [ ] [ ]

CEOG STS 3.7.1-4 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Amendment XXX Attachment 1, Volume 10, Rev. 0, Page 20 of 485

Attachment 1, Volume 10, Rev. 0, Page 21 of 485 U2/U3 CTS 3.7.1 2 INSERT 1 Table 3.7.1-2 PSV-8401 PSV-8410 1085 PSV-8402 PSV-8411 1092 PSV-8403 PSV-8412 1099 PSV-8404 PSV-8413 1106 PSV-8405 PSV-8414 1113 PSV-8406 PSV-8415 1120 PSV-8407 PSV-8416 1127 PSV-8408 PSV-8417 1134 PSV-8409 PSV-8418 1140 Insert Page 3.7.1-4 Attachment 1, Volume 10, Rev. 0, Page 21 of 485

Attachment 1, Volume 10, Rev. 0, Page 22 of 485 JUSTIFICATION FOR DEVIATIONS ITS 3.7.1, MAIN STEAM SAFETY VALVES

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 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.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 22 of 485

Attachment 1, Volume 10, Rev. 0, Page 23 of 485 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 10, Rev. 0, Page 23 of 485

Attachment 1, Volume 10, Rev. 0, Page 24 of 485 MSSVs B 3.7.1 B 3.7 PLANT SYSTEMS B 3.7.1 Main Steam Safety Valves (MSSVs)

BASES BACKGROUND The primary purpose of the MSSVs is to provide overpressure protection for the secondary system. The MSSVs also provide protection against overpressurizing the reactor coolant pressure boundary (RCPB) by providing a heat sink for the removal of energy from the Reactor Coolant System (RCS) if the preferred heat sink, provided by the Condenser and Circulating Water System, is not available.

Nine Eight MSSVs are located on each main steam header, outside 10.3.2 containment, upstream of the main steam isolation valves, as described U in the FSAR, Section [5.2] (Ref. 1). The MSSV rated capacity passes the 1 must have sufficient capacity to limit the full steam flow at 102% RTP (100% + 2% for instrument error) with the secondary system pressure to 110% of the valves full open. This meets the requirements of the ASME Code, design pressure. Section III (Ref. 2). The MSSV design includes staggered setpoints, 5

2 according to Table 3.7.1-1, in the accompanying LCO, so that only the number of valves needed will actuate. Staggered setpoints reduce the potential for valve chattering because of insufficient steam pressure to fully open all valves following a turbine reactor trip.

APPLICABLE The design basis for the MSSVs comes from Reference 2. The MSSV's SAFETY purpose is to limit secondary system pressure to 110% of design ANALYSES pressure when passing 100% of design steam flow. This design basis is sufficient to cope with any anticipated operational occurrence (AOO) or accident considered in the Design Basis Accident (DBA) and transient analysis.

The events that challenge the MSSV relieving capacity, and thus RCS pressure, are those characterized as decreased heat removal events, and U

are presented in the FSAR, Section [15.2] (Ref. 3). Of these, the full 2 power loss of condenser vacuum (LOCV) event is the limiting AOO. An LOCV isolates the turbine and condenser, and terminates normal 2750 psia feedwater flow to the steam generators. Before delivery of auxiliary 1

feedwater to the steam generators, RCS pressure reaches 2630 psig.

This peak pressure is < 110% of the design pressure of 2500 psig, but psia high enough to actuate the pressurizer safety valves. The maximum relieving rate during the LOCV event is 2.5 E6 lb/hour, which is less than the rated capacity of two MSSVs. within the CEOG STS B 3.7.1-1 Rev. 3.1, 12/01/05 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 24 of 485

Attachment 1, Volume 10, Rev. 0, Page 25 of 485 MSSVs B 3.7.1 BASES APPLICABLE SAFETY ANALYSES (continued)

The limiting accident for peak RCS pressure is the full power feedwater line break (FWLB), inside containment, with the failure of the backflow check valve in the feedwater line from the affected steam generator.

Water from the affected steam generator is assumed to be lost through the break with minimal additional heat transfer from the RCS. With heat removal limited to the unaffected steam generator, the reduced heat transfer causes an increase in RCS temperature, and the resulting RCS fluid expansion causes an increase in pressure. The RCS pressure increases to 2730 psig, with the pressurizer safety valves providing 1 relief capacity. The maximum relieving rate of the MSSVs during the FWLB event is 2.5 E6 lb/hour, which is less than the rated capacity of two MSSVs.

Using conservative analysis assumptions, a small range of FWLB sizes less than a full double ended guillotine break produce an RCS pressure of 2765 psig for a period of 20 seconds; exceeding 110% (2750 psig) of design pressure. This is considered acceptable as RCS pressure is still well below 120% of design pressure where deformation may occur. The probability of this event is in the range of 4 E-6/year.

The MSSVs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO This LCO requires all MSSVs to be OPERABLE in compliance with Reference 2, even though this is not a requirement of the DBA analysis. 4 1 as specified in Tables 3.7.1-1 and 3.7.1-2.

This is because operation with less than the full number of MSSVs The LCO is met when requires limitations on allowable THERMAL POWER (to meet ve eight of the nine MSSVs 1 per steam generator are Reference 2 requirements), and adjustment to the Reactor Protection OPERABLE. Operation System trip setpoints. These limitations are according to those shown in with less than the required number of Table 3.7.1-1, Required Action A.1, and Required Action A.2 in the MSSVs per steam generator OPERABLE accompanying LCO. An MSSV is considered inoperable if it fails to open upon demand.

The OPERABILITY of the MSSVs is defined as the ability to open within the setpoint tolerances, relieve steam generator overpressure, and reseat when pressure has been reduced. The OPERABILITY of the MSSVs is determined by periodic surveillance testing in accordance with the Inservice Testing Program.

The lift settings, according to Table 3.7.1-2 in the accompanying LCO, correspond to ambient conditions of the valve at nominal operating temperature and pressure.

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

CEOG STS B 3.7.1-2 Rev. 3.1, 12/01/05 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 25 of 485

Attachment 1, Volume 10, Rev. 0, Page 26 of 485 MSSVs B 3.7.1 BASES five APPLICABILITY In MODE 1, a minimum of two MSSVs per steam generator are required 4 to be OPERABLE, according to Table 3.7.1-1 in the accompanying LCO, which is limiting and bounds all lower MODES. In MODES 2 and 3, both the ASME Code and the accident analysis require only one MSSV per steam generator to provide overpressure protection.

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

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

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

A.1 and A.2 An alternative to restoring the inoperable MSSV(s) to OPERABLE status is to reduce power so that the available MSSV relieving capacity meets Code requirements for the power level. Operation may continue provided the allowable THERMAL POWER is equal to the product of: 1) the ratio of the number of MSSVs available per steam generator to the total INSERT 1 number of MSSVs per steam generator, and 2) the ratio of the available relieving capacity to total steam flow, multiplied by 100%. 1 Allowable THERMAL POWER = (8 - N) x 109.2 8

required 5

With one or more MSSVs inoperable, the ceiling on the variable Linear Power Level -

High trip setpoint overpower trip is reduced to an amount over the allowable THERMAL 4 POWER equal to the band given for this trip, according to Table 3.7.1-1 in the accompanying LCO.

INSERT 2 SP = Allowable THERMAL POWER + 9.8 where: 1 SP = Reduced reactor trip setpoint in percent RTP. This is a ratio of the available relieving capacity over the total steam flow at rated power.

8 = Total number of MSSVs per steam generator.

N = Number of inoperable MSSVs on the steam generator with the greatest number of inoperable valves.

CEOG STS B 3.7.1-3 Rev. 3.1, 12/01/05 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 26 of 485

Attachment 1, Volume 10, Rev. 0, Page 27 of 485 B 3.7.1 1 INSERT 1 THERMAL POWER is limited to the relief capacity of the remaining MSSVs. This is accomplished by restricting THERMAL POWER so that the energy transfer to the most limiting Steam Generator is not greater than the available relief capacity in that Steam Generator.

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

1 INSERT 2

. The reduced reactor trip allowable values are based on a detailed analysis of the Loss of Condenser Vacuum with a Concurrent Single Failure event (Ref. 3). This analysis considered the concerns identified in NRC Information Notice 94-60 (Ref. 4).

Insert Page B 3.7.1-3 Attachment 1, Volume 10, Rev. 0, Page 27 of 485

Attachment 1, Volume 10, Rev. 0, Page 28 of 485 MSSVs B 3.7.1 BASES ACTIONS (continued) 109.2 = Ratio of MSSV relieving capacity at 110% steam generator design pressure to calculated steam flow rate at 100% RTP + 2% instrument uncertainty expressed as a 1 percentage (see text above).

9.8 = Band between the maximum THERMAL POWER and the variable overpower trip setpoint ceiling (Table 3.7.1-1).

The operator should limit the maximum steady state power level to some value slightly below this setpoint to avoid an inadvertent overpower trip.

The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time for Required Action A.1 is a reasonable time period to reduce power level and is based on the low probability of an event occurring during this period that would require activation of the MSSVs. An additional 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months is allowed in Required Action A.2 to reduce the setpoints. The Completion Time of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months for Required Action A.2 is based on a reasonable time to correct the MSSV inoperability, the time required to perform the power reduction, operating experience in resetting all channels of a protective function, and on the low probability of the occurrence of a transient that could result in steam generator overpressure during this period.

B.1 and B.2 If the MSSVs cannot be restored to OPERABLE status in the associated Completion Time, or if one or more steam generators have less than two MSSVs OPERABLE, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 within [12] hours. The 2 allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.1.1 REQUIREMENTS This SR verifies the OPERABILITY of the MSSVs by the verification of each MSSV lift setpoints in accordance with the Inservice Testing 5 6

Program. The ASME Code (Ref. 4), requires that safety and relief valve 1 tests be performed in accordance with ANSI/ASME OM-1-1987 (Ref. 5).

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

Code, 1998 Edition through 2000 Addenda, Appendix I - Inservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants CEOG STS B 3.7.1-4 Rev. 3.1, 12/01/05 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 28 of 485

Attachment 1, Volume 10, Rev. 0, Page 29 of 485 MSSVs B 3.7.1 BASES SURVEILLANCE REQUIREMENTS (continued)

a. Visual examination, ;

b. Seat tightness determination, ; 3

c. Setpoint pressure determination (lift setting), ; and

d. Compliance with owner's seat tightness criteria, and .

e. Verification of the balancing device integrity on balanced valves.

ASME OM Code The ANSI/ASME Standard requires that all valves be tested every 1 5 years, and a minimum of 20% of the valves be tested every 24 months.

The ASME Code specifies the activities and frequencies necessary to + 2% / - 3%

satisfy the requirements. Table 3.7.1-2 allows a + [3]% setpoint tolerance 4 2 for OPERABILITY; however, the valves are reset to + 1% during the Surveillance to allow for drift.

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

REFERENCES 1. FSAR, Section [5.2]. 10.3.2 U

2. ASME, Boiler and Pressure Vessel Code,Section III, Article 3

NC-7000, Class 2 Components.

U

3. FSAR, Section [15.2]. 1

4. NRC Information Notice 94-60.

5

4. ASME Code for Operation and Maintenance of Nuclear Power Plants.

6 ASME OM Code, 1998 Edition through 2000 Addenda, Appendix I -

5. ANSI/ASME OM-1-1987. Inservice Testing of Pressure Relief Devices in Light-Water Reactor Nuclear Power Plants 1

CEOG STS B 3.7.1-5 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 29 of 485

Attachment 1, Volume 10, Rev. 0, Page 30 of 485 JUSTIFICATION FOR DEVIATIONS ITS 3.7.1 BASES, MAIN STEAM SAFETY VALVES

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 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.

3. 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.

4. The ISTS Tables were modified to reflect SONGS specific requirements for MSSV Operability and; therefore, the ISTS Bases was also revised to reflect the changes made.

5. The Number for the Table in the ISTS Bases (ISTS Table 3.7.1-1) which references the MSSV staggered setpoints is actually Table 3.7.1-2 in the ISTS Specifications and in the SONGS Units 2 and 3 ITS Bases. Also, the term required was added to the ISTS Bases where necessary to be consistent with the ISTS.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 30 of 485

Attachment 1, Volume 10, Rev. 0, Page 31 of 485 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 10, Rev. 0, Page 31 of 485

Attachment 1, Volume 10, Rev. 0, Page 32 of 485 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.1, MAIN STEAM SAFETY VALVES There are no specific No Significant Hazards Considerations for this Specification.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 32 of 485

, Volume 10, Rev. 0, Page 33 of 485 ATTACHMENT 2 ITS 3.7.2, MAIN STEAM ISOLATION VALVES , Volume 10, Rev. 0, Page 33 of 485

, Volume 10, Rev. 0, Page 34 of 485 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 10, Rev. 0, Page 34 of 485

Attachment 1, Volume 10, Rev. 0, Page 35 of 485 ITS MSIVs A01 3.7.2 3.7 PLANT SYSTEMS 3.7.2 Main Steam Isolation Valves (MSIVs)

LCO 3.7.2 LCO 3.7.2 Two MSIVs shall be OPERABLE.

Applicability APPLICABILITY: MODE 1, MODES 2 and 3 except when all MSIVs are closed and deactivated.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One MSIV inoperable in A.1 Restore MSIV to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months MODE 1. OPERABLE status.

ACTION B B. Required Action and B.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Associated Completion Time of Condition A not met.

ACTION C C. ---------NOTE--------- C.1 Close MSIV. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Separate Condition entry is allowed for AND each MSIV.

C.2 Verify MSIV is Once per 7 days closed.

One or more MSIVs inoperable in MODE 2 or 3.

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

D.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SAN ONOFRE--UNIT 2 3.7-5 Amendment No. 127 Attachment 1, Volume 10, Rev. 0, Page 35 of 485

Attachment 1, Volume 10, Rev. 0, Page 36 of 485 ITS MSIVs 3.7.2 A01 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 SR 3.7.2.1 Verify closure time of each MSIV is In accordance LA01

8.0 seconds. with the Inservice within limits Testing Program INSERT 1 M01 SAN ONOFRE--UNIT 2 3.7-6 Amendment No. 127 Attachment 1, Volume 10, Rev. 0, Page 36 of 485

Attachment 1, Volume 10, Rev. 0, Page 37 of 485 ITS 3.7.2 M01 INSERT 1 SR 3.7.2.2 SR 3.7.2.2 Verify each MSIV actuates to the isolation position In accordance on an actual or simulated actuation signal. with the Surveillance Frequency Control Program Insert Page 3.7-6 Attachment 1, Volume 10, Rev. 0, Page 37 of 485

Attachment 1, Volume 10, Rev. 0, Page 38 of 485 ITS MSIVs A01 3.7.2 3.7 PLANT SYSTEMS 3.7.2 Main Steam Isolation Valves (MSIVs)

LCO 3.7.2 LCO 3.7.2 Two MSIVs shall be OPERABLE.

Applicability APPLICABILITY: MODE 1, MODES 2 and 3 except when all MSIVs are closed and deactivated.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One MSIV inoperable in A.1 Restore MSIV to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months MODE 1. OPERABLE status.

ACTION B B. Required Action and B.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Associated Completion Time of Condition A not met.

ACTION C C. ---------NOTE--------- C.1 Close MSIV. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Separate Condition entry is allowed for AND each MSIV.

C.2 Verify MSIV is Once per 7 days closed.

One or more MSIVs inoperable in MODE 2 or 3.

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

D.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SAN ONOFRE--UNIT 3 3.7-5 Amendment No. 116 Attachment 1, Volume 10, Rev. 0, Page 38 of 485

Attachment 1, Volume 10, Rev. 0, Page 39 of 485 ITS MSIVs 3.7.2 A01 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 SR 3.7.2.1 Verify closure time of each MSIV is In accordance LA01

8.0 seconds. with the Inservice within limits Testing Program INSERT 1 M01 SAN ONOFRE--UNIT 3 3.7-6 Amendment No. 116 Attachment 1, Volume 10, Rev. 0, Page 39 of 485

Attachment 1, Volume 10, Rev. 0, Page 40 of 485 ITS 3.7.2 M01 INSERT 1 SR 3.7.2.2 SR 3.7.2.2 Verify each MSIV actuates to the isolation position In accordance on an actual or simulated actuation signal. with the Surveillance Frequency Control Program Insert Page 3.7-6 Attachment 1, Volume 10, Rev. 0, Page 40 of 485

Attachment 1, Volume 10, Rev. 0, Page 41 of 485 DISCUSSION OF CHANGES ITS 3.7.2, MAIN STEAM ISOLATION VALVES ADMINISTRATIVE CHANGES A01 In the conversion of the San Onofre Nuclear Generating Station (SONGS)

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

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

MORE RESTRICTIVE CHANGES M01 CTS 3.7.2 does not include a requirement to verify that each MSIV actuates to the isolation position on an actual or simulated actuation signal. ITS 3.7.2 contains an SR (SR 3.7.2.2) to verify that each MSIV actuates to the isolation position on an actual or simulated actuation signal at a Frequency that will be specified in the Surveillance Frequency Control Program. This changes the CTS by adding a new Surveillance Requirement.

The purpose of ITS SR 3.7.2.2 is to verify that the MSIVs can close on an actual or simulated actuation signal. This change is acceptable because the test is conducted to ensure that the MSIVs will perform their safety function. The Frequency for this new SR will be specified in the Surveillance Frequency Control Program. The initial Frequency specified will be 24 months, which is consistent with the current SONGS refueling outage Surveillance interval. Any change to this 24 month Frequency will be made in accordance with the Surveillance Frequency Control Program. This change is considered more restrictive because a new Surveillance Requirement is added to the ITS that is not included in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Detail for Meeting TS Requirements or Reporting Requirements) CTS SR 3.7.2.1 requires verification that the closure time of each MSIV is 8.0 seconds. ITS SR 3.7.2.1 requires verification that the closure time of each MSIV is within limits. This changes the CTS by moving the MSIV closure time limit to the Licensee Controlled Specifications (LCS).

The removal of MSIV closure times from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications in order to provide adequate protection of public health San Onofre Unit 2 and 3 Page 1 of 2 Attachment 1, Volume 10, Rev. 0, Page 41 of 485

Attachment 1, Volume 10, Rev. 0, Page 42 of 485 DISCUSSION OF CHANGES ITS 3.7.2, MAIN STEAM ISOLATION VALVES and safety. The ITS retains the requirement to verify that the isolation time of each MSIV is within limits. Also, this change is acceptable because these types of procedural details will be adequately controlled in the LCS. The LCS is incorporated by reference into the UFSAR and any changes to the LCS are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because a procedural detail for meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES None San Onofre Unit 2 and 3 Page 2 of 2 Attachment 1, Volume 10, Rev. 0, Page 42 of 485

Attachment 1, Volume 10, Rev. 0, Page 43 of 485 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 10, Rev. 0, Page 43 of 485

Attachment 1, Volume 10, Rev. 0, Page 44 of 485 U2/U3 CTS MSIVs 3.7.2 3.7 PLANT SYSTEMS 3.7.2 Main Steam Isolation Valves (MSIVs)

LCO 3.7.2 LCO 3.7.2 [Two] MSIVs shall be OPERABLE. 2 Applicability APPLICABILITY: MODE 1, MODES 2 and 3 except when all MSIVs are closed [and de-activated]. 2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One MSIV inoperable in A.1 Restore MSIV to [8] hours 2 MODE 1. OPERABLE status.

ACTION B B. Required Action and B.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Associated Completion Time of Condition A not met.

ACTION C C. ------------NOTE------------ C.1 Close MSIV. [8] hours 2 Separate Condition entry is allowed for each AND MSIV.

C.2 Verify MSIV is closed. Once per 7 days One or more MSIVs inoperable in MODE 2 or 3.

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

2 D.2 Be in MODE 4. [12] hours CEOG STS 3.7.2-1 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Amendment XXX Attachment 1, Volume 10, Rev. 0, Page 44 of 485

Attachment 1, Volume 10, Rev. 0, Page 45 of 485 U2/U3 CTS MSIVs 3.7.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.2.1 SR 3.7.2.1 -------------------------------NOTE------------------------------

3 Only required to be performed in MODES 1 and 2.

Verify the isolation time of each MSIV is In accordance TSTF-

[4.6] seconds. with the Inservice 491-A within limits Testing Program DOC M01 SR 3.7.2.2 -------------------------------NOTE------------------------------

Only required to be performed in MODES 1 and 2. 3 TSTF-Verify each MSIV actuates to the isolation position [18] months 425-A on an actual or simulated actuation signal.

In accordance with the Surveillance Frequency Control Program CEOG STS 3.7.2-2 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Amendment XXX Attachment 1, Volume 10, Rev. 0, Page 45 of 485

Attachment 1, Volume 10, Rev. 0, Page 46 of 485 JUSTIFICATION FOR DEVIATIONS ITS 3.7.2, MAIN STEAM ISOLATION VALVES

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 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.

3. ISTS SR 3.7.2.1 and SR 3.7.2.2 are modified by a Note which states, "Only required to be performed in MODES 1 and 2." This Note is being deleted for the SONGS Units 2 and 3 ITS. The SONGS Units 2 and 3 valves are pneumatic/hydraulic valves which do not require detailed testing at design operating temperature and pressure, but instead the testing relies on stroke time and detailed calculations/analysis. This change is acceptable because SONGS Units 2 and 3 do not need to be at normal operating temperature and pressure to perform these surveillances, thus SCE normally performs these surveillances in MODES 4, 5, or 6. This change is consistent with SONGS CTS SR 3.7.2.1.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 46 of 485

Attachment 1, Volume 10, Rev. 0, Page 47 of 485 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 10, Rev. 0, Page 47 of 485

Attachment 1, Volume 10, Rev. 0, Page 48 of 485 MSIVs B 3.7.2 B 3.7 PLANT SYSTEMS B 3.7.2 Main Steam Isolation Valves (MSIVs)

BASES BACKGROUND The MSIVs isolate steam flow from the secondary side of the steam generators following a high energy line break (HELB). MSIV closure terminates flow from the unaffected (intact) steam generator.

One MSIV is located in each main steam line outside, but close to, containment. The MSIVs are downstream from the main steam safety valves (MSSVs), atmospheric dump valves, and auxiliary feedwater pump turbine steam supplies to prevent their being isolated from the steam generators by MSIV closure. Closing the MSIVs isolates each steam generator from the other, and isolates the turbine, Steam Bypass System, and other auxiliary steam supplies from the steam generators.

M S I S (MSIS) 6 and on Containment The MSIVs close on a main steam isolation signal generated by either Isolation Actuation Signal (CIAS) by low steam generator pressure or high containment pressure. The MSIVs 1 fail closed on loss of control or actuation power. The MSIS also actuates and CIAS the main feedwater isolation valves (MFIVs) to close. The MSIVs may also be actuated manually.

U A description of the MSIVs is found in the FSAR, Section [10.3] (Ref. 1). 1 2 APPLICABLE The design basis of the MSIVs is established by the containment analysis SAFETY for the large steam line break (SLB) inside containment, as discussed in U

ANALYSES the FSAR, Section [6.2] (Ref. 2). It is also influenced by the accident 1 2 U

analysis of the SLB events presented in the FSAR, Section [15.1.5]

(Ref. 3). The design precludes the blowdown of more than one steam generator, assuming a single active component failure (e.g., the failure of 3 one MSIV to close on demand).

The limiting case for the containment analysis is the hot zero power SLB inside containment with a loss of offsite power following turbine trip, and failure of the MSIV on the affected steam generator to close. At zero power, the steam generator inventory and temperature are at their maximum, maximizing the analyzed mass and energy release to the containment. Due to reverse flow, failure of the MSIV to close contributes to the total release of the additional mass and energy in the steam headers, which are downstream of the other MSIV. With the most reactive rod cluster control assembly assumed stuck in the fully 1 element single 1

CEOG STS B 3.7.2-1 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 48 of 485

Attachment 1, Volume 10, Rev. 0, Page 49 of 485 MSIVs B 3.7.2 BASES APPLICABLE SAFETY ANALYSES (continued) withdrawn position, there is an increased possibility that the core will become critical and return to power. The core is ultimately shut down by the borated water injection delivered by the Emergency Core Cooling System. Other failures considered are the failure of an MFIV to close, and failure of an emergency diesel generator to start.

The accident analysis compares several different SLB events against different acceptance criteria. The large SLB outside containment upstream of the MSIV is limiting for offsite dose, although a break in this short section of main steam header has a very low probability. The large SLB inside containment at hot zero power is the limiting case for a post trip return to power. The analysis includes scenarios with offsite power available and with a loss of offsite power following turbine trip.

With offsite power available, the reactor coolant pumps continue to circulate coolant through the steam generators, maximizing the Reactor Coolant System (RCS) cooldown. With a loss of offsite power, the response of mitigating systems, such as the high pressure safety injection (HPSI) pumps, is delayed. Significant single failures considered include:

failure of a MSIV to close, failure of an emergency diesel generator, and failure of a HPSI pump.

to close 1

The MSIVs serve only a safety function and remain open during power operation. These valves operate under the following situations:

a. An HELB inside containment. In order to maximize the mass and energy release into the containment, the analysis assumes that the MSIV in the affected steam generator remains open. For this accident scenario, steam is discharged into containment from both steam generators until closure of the MSIV in the intact steam generator occurs. After MSIV closure, steam is discharged into containment only from the affected steam generator, and from the residual steam in the main steam header downstream of the closed MSIV in the intact loop.

b. A break outside of containment and upstream from the MSIVs. This scenario is not a containment pressurization concern. The uncontrolled blowdown of more than one steam generator must be prevented to limit the potential for uncontrolled RCS cooldown and positive reactivity addition. Closure of the MSIVs isolates the break, and limits the blowdown to a single steam generator.

1 CEOG STS B 3.7.2-2 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 49 of 485

Attachment 1, Volume 10, Rev. 0, Page 50 of 485 MSIVs B 3.7.2 BASES APPLICABLE SAFETY ANALYSES (continued)

c. A break downstream of the MSIVs. This type of break will be isolated by the closure of the MSIVs. Events such as increased steam flow through the turbine or the steam bypass valves will also terminate on closure of the MSIVs.

d. A steam generator tube rupture. For this scenario, closure of the MSIV[s] isolates the affected steam generator from the intact steam 2 generator. In addition to minimizing radiological releases, this enables the operator to maintain the pressure of the steam generator with the ruptured tube below the MSSV setpoints, a necessary step toward isolating the flow through the rupture.

e. The MSIVs are also utilized during other events such as a feedwater line break. These events are less limiting so far as MSIV OPERABILITY is concerned.

The MSIVs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO This LCO requires that the MSIV in each of the [two] steam lines be 2 OPERABLE. The MSIVs are considered OPERABLE when the isolation times are within limits, and they close on an isolation actuation signal.

This LCO provides assurance that the MSIVs will perform their design 10 CFR 50.67 (Ref. 5) limits, as safety function to mitigate the consequences of accidents that could result appropriate in offsite exposures comparable to the 10 CFR 100 (Ref. 4) limits or the 7 NRC staff approved licensing basis.

APPLICABILITY The MSIVs must be OPERABLE in MODE 1 and in MODES 2 and 3 except when all MSIVs are closed and [deactivated]. In these MODES 2 there is significant mass and energy in the RCS and steam generators.

When the MSIVs are closed, they are already performing their safety function.

In MODE 4, the steam generator energy is low; therefore, the MSIVs are not required to be OPERABLE.

In MODES 5 and 6, the steam generators do not contain much energy because their temperature is below the boiling point of water; therefore, the MSIVs are not required for isolation of potential high energy secondary system pipe breaks in these MODES.

1 CEOG STS B 3.7.2-3 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 50 of 485

Attachment 1, Volume 10, Rev. 0, Page 51 of 485 MSIVs B 3.7.2 BASES ACTIONS A.1 With one MSIV inoperable in MODE 1, time is allowed to restore the component to OPERABLE status. Some repairs can be made to the MSIV with the unit hot. The [8] hour Completion Time is reasonable, 2 considering the probability of an accident occurring during the time period that would require closure of the MSIVs.

The [8] hour Completion Time is greater than that normally allowed for 2 containment isolation valves because the MSIVs are valves that isolate a closed system penetrating containment. These valves differ from other containment isolation valves in that the closed system provides an additional means for containment isolation.

B.1 If the MSIV cannot be restored to OPERABLE status within [8] hours, the 2 unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Condition C would be entered. The Completion Time is reasonable, based on operating experience, to reach MODE 2, and close the MSIVs in an orderly manner and without challenging unit systems.

C.1, C.2.1, and C.2.2 3 Condition C is modified by a Note indicating that separate Condition entry is allowed for each MSIV.

Since the MSIVs are required to be OPERABLE in MODES 2 and 3, the inoperable MSIVs may either be restored to OPERABLE status or closed.

When closed, the MSIVs are already in the position required by the assumptions in the safety analysis.

2 The [8] hour Completion Time is consistent with that allowed in Condition A.

Inoperable MSIVs that cannot be restored to OPERABLE status within the specified Completion Time, but are closed, must be verified on a periodic basis to be closed. This is necessary to ensure that the assumptions in the safety analysis remain valid. The 7 day Completion Time is reasonable, based on engineering judgment, MSIV status indications available in the control room, and other administrative controls, to ensure these valves are in the closed position.

1 CEOG STS B 3.7.2-4 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 51 of 485

Attachment 1, Volume 10, Rev. 0, Page 52 of 485 MSIVs B 3.7.2 BASES ACTIONS (continued)

D.1 and D.2 If the MSIVs cannot be restored to OPERABLE status, or closed, within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 within

[12] hours. The allowed Completion Times are reasonable, based on 2 operating experience, to reach the required unit conditions from MODE 2 conditions in an orderly manner and without challenging unit systems.

within the limit given SURVEILLANCE SR 3.7.2.1 in Reference 6 and is within that REQUIREMENTS This SR verifies that the closure time of each MSIV is [4.6] seconds.

This SR also verifies the The MSIV isolation time is assumed in the accident and containment valve closure time is in analyses. This SR is normally performed upon returning the unit to 8 TSTF-accordance with the Inservice Testing Program. operation following a refueling outage. The MSIVs should not be tested 491-A at power since even a part stroke exercise increases the risk of a valve prior to MODE 3 during closure with the unit generating power. As the MSIVs are not tested at power, they are exempt from the ASME Code (Ref. 5), requirements 6 during operation in MODES 1 and 2. 7 The Frequency for this SR is in accordance with the Inservice Testing Program.

This test is conducted in MODE 3, with the unit at operating temperature and pressure. This SR is modified by a Note that allows entry into and 9

operation in MODE 3 prior to performing the SR. This allows a delay of testing until MODE 3, in order to establish conditions consistent with those under which the acceptance criterion was generated.

SR 3.7.2.2 This SR verifies that each MSIV can close on an actual or simulated actuation signal. This Surveillance is normally performed upon returning 8 the plant to operation following a refueling outage. The Frequency of MSIV testing is every [18] months. The [18] month Frequency for testing TSTF-425-A prior to MODE 3 during is based on the refueling cycle. Operating experience has shown that these components usually pass the Surveillance when performed at the

[18] month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint. INSERT 1 1

CEOG STS B 3.7.2-5 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 52 of 485

Attachment 1, Volume 10, Rev. 0, Page 53 of 485 B 3.7.2 TSTF-425-A INSERT 1 The Frequency is controlled under the Surveillance Frequency Control Program. 5

Reviewers Note ---------------------------------------------------

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

Insert Page B 3.7.2-5 Attachment 1, Volume 10, Rev. 0, Page 53 of 485

Attachment 1, Volume 10, Rev. 0, Page 54 of 485 MSIVs B 3.7.2 BASES REFERENCES 1. FSAR, Section [10.3].

U

2. FSAR, Section [6.2]. 3 1 2

3. FSAR, Section [15.1.5]. Licensee Controlled Specifications.

U

5. 10 CFR 50.67.

4. 10 CFR 100.11.

7

6. Technical Requirements Manual 1 TSTF-7 5. ASME Code for Operation and Maintenance of Nuclear Power 491-A Plants.

1 CEOG STS B 3.7.2-6 Rev. 3.1, 12/01/05 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 54 of 485

Attachment 1, Volume 10, Rev. 0, Page 55 of 485 JUSTIFICATION FOR DEVIATIONS ITS 3.7.2 BASES, MAIN STEAM ISOLATION VALVES

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 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.

3. Changes are made to be consistent with the actual Specification.

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

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

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 ITS 3.7.2 Bases (LCO Section) is being revised to add reference to 10 CFR 50.67 to reflect that the MSLB event is evaluated using 10 CFR 50.67 for offsite dose limits (SONGS is approved for Alternative Source Term).

8. ISTS SR 3.7.2.1 and 3.7.2.2 Bases (first paragraph) states, "This SR is normally performed upon returning the unit to operation following a refueling outage." This statement will be revised to read, "The SR is normally performed prior to MODE 3 during a refueling outage." This is acceptable because this SR is normally performed at SONGS Units 2 and 3 in MODE 4, 5, or 6, thus using the ISTS wording "following a refueling outage" would not be correct. This change is related to the deletion of the ISTS SR 3.7.2.1 and SR 3.7.2.2 Note, which is justified by JFD 3 for the ITS Markup. This JFD discusses that SONGS Units 2 and 3 valves are pneumatic/hydraulic valves and do not require detailed testing at design operating temperature and pressure. Instead the testing relies on stroke time and detailed calculations/analysis.

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

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 55 of 485

Attachment 1, Volume 10, Rev. 0, Page 56 of 485 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 10, Rev. 0, Page 56 of 485

Attachment 1, Volume 10, Rev. 0, Page 57 of 485 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.2, MAIN STEAM ISOLATION VALVES There are no specific No Significant Hazards Considerations for this Specification.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 57 of 485

Attachment 1, Volume 10, Rev. 0, Page 58 of 485 ATTACHMENT 3 ITS 3.7.3, MAIN FEEDWATER ISOLATION VALVES (MFIVs)

Attachment 1, Volume 10, Rev. 0, Page 58 of 485

, Volume 10, Rev. 0, Page 59 of 485 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 10, Rev. 0, Page 59 of 485

Attachment 1, Volume 10, Rev. 0, Page 60 of 485 ITS MFIVs A01 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Main Feedwater Isolation Valves (MFIVs).

LCO 3.7.3 LCO 3.7.3 Two MFIVs shall be OPERABLE.

Applicability APPLICABILITY: MODES 1, 2, and 3 except when MFIV is closed and deactivated.

ACTIONS

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

ACTION Separate Condition entry is allowed for each valve.

Note CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One or more MFIVs A.1 Close or isolate 7 days inoperable. inoperable MFIV.

AND A.2 Verify inoperable Once per 7 days MFIV valve is closed or isolated.

ACTION B B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SAN ONOFRE--UNIT 2 3.7-7 Amendment No. 127 Attachment 1, Volume 10, Rev. 0, Page 60 of 485

Attachment 1, Volume 10, Rev. 0, Page 61 of 485 ITS MFIVs 3.7.3 3.7 PLANT SYSTEMS A01 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 SR 3.7.3.1 Verify the closure time of each MFIV In accordance

10 seconds. with the LA01 Inservice within limits Testing Program SR 3.7.3.2 INSERT 1 M01 SAN ONOFRE--UNIT 2 3.7-8 Amendment No. 127 Attachment 1, Volume 10, Rev. 0, Page 61 of 485

Attachment 1, Volume 10, Rev. 0, Page 62 of 485 ITS 3.7.3 M01 INSERT 1 SR 3.7.3.2 SR 3.7.3.2 Verify each MFIV actuates to the isolation position In accordance on an actual or simulated actuation signal. with the Surveillance Frequency Control Program Insert Page 3.7-8 Attachment 1, Volume 10, Rev. 0, Page 62 of 485

Attachment 1, Volume 10, Rev. 0, Page 63 of 485 ITS MFIVs A01 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Main Feedwater Isolation Valves (MFIVs).

LCO 3.7.3 LCO 3.7.3 Two MFIVs shall be OPERABLE.

Applicability APPLICABILITY: MODES 1, 2, and 3 except when MFIV is closed and deactivated.

ACTIONS

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

ACTION Separate Condition entry is allowed for each valve.

Note CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One or more MFIVs A.1 Close or isolate 7 days inoperable. inoperable MFIV.

AND A.2 Verify inoperable Once per 7 days MFIV valve is closed or isolated.

ACTION B B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SAN ONOFRE--UNIT 3 3.7-7 Amendment No. 116 Attachment 1, Volume 10, Rev. 0, Page 63 of 485

Attachment 1, Volume 10, Rev. 0, Page 64 of 485 ITS MFIVs 3.7.3 3.7 PLANT SYSTEMS A01 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 SR 3.7.3.1 Verify the closure time of each MFIV In accordance

10 seconds. with the LA01 Inservice within limits Testing Program SR 3.7.3.2 INSERT 1 M01 SAN ONOFRE--UNIT 3 3.7-8 Amendment No. 116 Attachment 1, Volume 10, Rev. 0, Page 64 of 485

Attachment 1, Volume 10, Rev. 0, Page 65 of 485 ITS 3.7.3 M01 INSERT 1 SR 3.7.3.2 SR 3.7.3.2 Verify each MFIV actuates to the isolation position In accordance on an actual or simulated actuation signal. with the Surveillance Frequency Control Program Insert Page 3.7-8 Attachment 1, Volume 10, Rev. 0, Page 65 of 485

Attachment 1, Volume 10, Rev. 0, Page 66 of 485 DISCUSSION OF CHANGES ITS 3.7.3, MAIN FEEDWATER ISOLATION VALVES (MFIVs)

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

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

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

MORE RESTRICTIVE CHANGES M01 CTS 3.7.3 does not include a requirement to verify that each MFIV actuates to the isolation position on an actual or simulated actuation signal. ITS 3.7.3 contains an SR (SR 3.7.3.2) to verify that each MFIV actuates to the isolation position on an actual or simulated actuation signal at a Frequency that will be specified in the Surveillance Frequency Control Program. This changes the CTS by adding a new Surveillance Requirement.

The purpose of ITS SR 3.7.3.2 is to verify that the MFIVs can close on an actual or simulated actuation signal. This change is acceptable because the test is conducted to ensure that the MFIVs will perform their safety function. The Frequency for this new SR will be specified in the Surveillance Frequency Control Program. The initial Frequency specified will be 24 months, which is consistent with the current SONGS refueling outage Surveillance interval. Any change to this 24 month Frequency will be made in accordance with the Surveillance Frequency Control Program. This change is considered more restrictive because a new Surveillance Requirement is added to the ITS that is not included in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Detail for Meeting TS Requirements or Reporting Requirements) CTS SR 3.7.3.1 requires verification that the closure time of each MFIV is 10.0 seconds. ITS SR 3.7.3.1 requires verification that the closure time of each MFIV is within limits. This changes the CTS by moving the MFIV closure time limit to the Licensee Controlled Specifications (LCS).

The removal of MFIV closure times from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications in order to provide adequate protection of public health San Onofre Unit 2 and 3 Page 1 of 2 Attachment 1, Volume 10, Rev. 0, Page 66 of 485

Attachment 1, Volume 10, Rev. 0, Page 67 of 485 DISCUSSION OF CHANGES ITS 3.7.3, MAIN FEEDWATER ISOLATION VALVES (MFIVs) and safety. The ITS retains the requirement to verify that the isolation time of each MFIV is within limits. Also, this change is acceptable because these types of procedural details will be adequately controlled in the LCS. The LCS is incorporated by reference into the UFSAR and any changes to the LCS are made under 10 CFR 50.59, which ensures changes are properly evaluated. This change is designated as a less restrictive removal of detail change because a procedural detail for meeting Technical Specification requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES None San Onofre Unit 2 and 3 Page 2 of 2 Attachment 1, Volume 10, Rev. 0, Page 67 of 485

Attachment 1, Volume 10, Rev. 0, Page 68 of 485 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 10, Rev. 0, Page 68 of 485

Attachment 1, Volume 10, Rev. 0, Page 69 of 485 U2/U3 CTS MFIVs [and [MFIV] Bypass Valves] 2 3.7.3 3.7 PLANT SYSTEMS 3.7.3 Main Feedwater Isolation Valves (MFIVs) [and [MFIV] Bypass Valves]

LCO 3.7.3 LCO 3.7.3 [Two] MFIVs [and [MFIV] bypass valves] shall be OPERABLE.

Applicability APPLICABILITY: MODES 1, 2, [and 3] except when MFIV [or [MFIV] bypass valve] is closed and [de-activated] or [isolated by a closed manual valve].

ACTIONS

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

ACTION Separate Condition entry is allowed for each valve.

Note CONDITION REQUIRED ACTION COMPLETION TIME 2

ACTION A A. One or more MFIVs [or A.1 Close or isolate inoperable [8 or 72] hours 3

[MFIV] bypass valves] MFIV [or [MFIV] bypass 7 days inoperable. valve].

AND A.2 Verify inoperable MFIV [or Once per 7 days

[MFIV] bypass valve] is closed or isolated.

B. [ [Two] valves in the B.1 Isolate affected flow path. 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months same flow path inoperable. AND B.2 Verify inoperable MFIV [or Once per 7 days ]

[MFIV] bypass valve] is closed or isolated.

ACTION B 1 C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion B B 2 Time not met. [ AND C.2 Be in MODE 4. [12] hours ] 1 2 B

CEOG STS 3.7.3-1 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Amendment XXX Attachment 1, Volume 10, Rev. 0, Page 69 of 485

Attachment 1, Volume 10, Rev. 0, Page 70 of 485 U2/U3 CTS MFIVs [and [MFIV] Bypass Valves] 2 3.7.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.3.1 SR 3.7.3.1 Verify the isolation time of each MFIV [and [MFIV] In accordance 2 TSTF-bypass valve] is [7] seconds. with the Inservice 491-A within limits Testing Program DOC M01 TSTF-SR 3.7.3.2 Verify each MFIV [and [MFIV] bypass valve] [18] months 2 425-A actuates to the isolation position on an actual or simulated actuation signal. In accordance with the Surveillance Frequency Control Program CEOG STS 3.7.3-2 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Amendment XXX Attachment 1, Volume 10, Rev. 0, Page 70 of 485

Attachment 1, Volume 10, Rev. 0, Page 71 of 485 JUSTIFICATION FOR DEVIATIONS ITS 3.7.3, MAIN FEEDWATER ISOLATION VALVES (MFIVs)

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 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.

3. The ISTS 3.7.3 ACTION A Completion Time to close or isolate the inoperable MFIV when one or more MFIVs are inoperable is bracketed with 8 or 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months contained within the brackets. This change incorporates 7 days for the SONGS ITS 3.7.3 ACTION A Completion Time to close or isolate the inoperable MFIV when one or more MFIVs are inoperable. The 7 day Completion Time is the value contained in the SONGS CTS and will be adopted in the SONGS ITS. The 7 day Completion Time takes into account the redundancy afforded by the remaining OPERABLE valves, and the low probability of an event occurring during this time period that would require isolation of the MFW flow path.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 71 of 485

Attachment 1, Volume 10, Rev. 0, Page 72 of 485 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 10, Rev. 0, Page 72 of 485

Attachment 1, Volume 10, Rev. 0, Page 73 of 485 MFIVs [and [MFIV] Bypass Valves] 2 B 3.7.3 B 3.7 PLANT SYSTEMS 2

B 3.7.3 Main Feedwater Isolation Valves (MFIVs) [and [MFIV] Bypass Valves]

BASES BACKGROUND The MFIVs isolate main feedwater (MFW) flow to the secondary side of the steam generators following a high energy line break (HELB). Closure of the MFIVs and the bypass valves terminates flow to both steam 1 generators, terminating the event for feedwater line breaks (FWLBs) occurring upstream of the MFIVs. The consequences of events occurring in the main steam lines or in the MFW lines downstream of the MFIVs will be mitigated by their closure. Closure of the MFIVs and bypass valves 1 effectively terminates the addition of feedwater to an affected steam generator, limiting the mass and energy release for steam line breaks (SLBs) or FWLBs inside containment, and reducing the cooldown effects for SLBs.

1 The MFIVs and bypass valves isolate the nonsafety related portions from the safety related portion of the system. In the event of a secondary side pipe rupture inside containment, the valves limit the quantity of high energy fluid that enters containment through the break, and provide a pressure boundary for the controlled addition of auxiliary feedwater (AFW) to the intact loop.

M 1

One MFIV is located on each AFW line, outside, but close to, containment. The MFIVs are located upstream of the AFW injection point so that AFW may be supplied to a steam generator following MFIV closure. The piping volume from the valve to the steam generator must be accounted for in calculating mass and energy releases, and refilled prior to AFW reaching the steam generator following either an SLB or FWLB.

The MFIVs and its bypass valves close on receipt of a main steam on receipt of a containment isolation signal (MSIS) generated by either low steam generator pressure and isolation actuation signal or high containment pressure. The MSIS also actuates the main steam CIAS 1

(CIAS) isolation valves (MSIVs) to close. The MFIVs and bypass valves may also be actuated manually. In addition to the MFIVs and the bypass valves, a check valve inside containment is available to isolate the feedwater line penetrating containment, and to ensure that the consequences of events do not exceed the capacity of the containment heat removal systems.

2 A description of the MFIVs is found in the FSAR, Section [10.4.7] (Ref. 1). 1 U

CEOG STS B 3.7.3-1 Rev. 3.1, 12/01/05 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 73 of 485

Attachment 1, Volume 10, Rev. 0, Page 74 of 485 MFIVs [and [MFIV] Bypass Valves] 2 B 3.7.3 BASES APPLICABLE The design basis of the MFIVs is established by the analysis for the large SAFETY SLB. It is also influenced by the accident analysis for the large FWLB.

ANALYSES Closure of the MFIVs and their bypass valves may also be relied on to terminate a steam break for core response analysis and an excess feedwater flow event upon receipt of a MSIS on high steam generator 1 pressure level.

low Failure of an MFIV and the bypass valve to close following an SLB, FWLB, or excess feedwater flow event can result in additional mass and energy to the steam generators contributing to cooldown. This failure also results in additional mass and energy releases following an SLB or FWLB event.

The MFIVs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO This LCO ensures that the MFIVs and the bypass valves will isolate MFW 3 flow to the steam generators. Following an FWLB or SLB, these valves one will also isolate the nonsafety related portions from the safety related 2

portions of the system. This LCO requires that [two] MFIVs [and [MFIV]

bypass valves] in each feedwater line be OPERABLE. The MFIVs and 3

the bypass valves are considered OPERABLE when the isolation times are within limits, and are closed on an isolation actuation signal. 1 will MSIS and CIAS Failure to meet the LCO requirements can result in additional mass and energy being released to containment following an SLB or FWLB inside containment. If an MSIS on high steam generator level is relied on to 1

terminate an excess feedwater flow event, failure to meet the LCO may result in the introduction of water into the main steam lines.

APPLICABILITY The MFIVs and the bypass valves must be OPERABLE whenever there 3 is significant mass and energy in the Reactor Coolant System and steam generators. This ensures that, in the event of an HELB, a single failure cannot result in the blowdown of more than one steam generator.

s 2

In MODES 1, 2, and 3, the MFIV [or [MFIV] bypass valves] are required to be OPERABLE, except when they are closed and deactivated or isolated 3 by a closed manual valve, in order to limit the amount of available fluid that could be added to containment in the case of a secondary system pipe break inside containment. When the valves are closed and deactivated or isolated by a closed manual valve, they are already 3 performing their safety function.

In MODES 4, 5, and 6, steam generator energy is low. Therefore, the 3

MFIVs and the bypass valves are normally closed since MFW is not required.

CEOG STS B 3.7.3-2 Rev. 3.1, 12/01/05 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 74 of 485

Attachment 1, Volume 10, Rev. 0, Page 75 of 485 MFIVs [and [MFIV] Bypass Valves] 2 B 3.7.3 BASES ACTIONS The ACTIONS Table is modified by a Note indicating that separate Condition entry is allowed for each value.

A.1 and A.2 or more s 1

With one MFIV or the bypass valve inoperable, action must be taken to 3 7 days close or isolate the inoperable valves within [8 or 72] hours. When these valves are closed or isolated, they are performing their required safety function (e.g., to isolate the line).

For units with only one MFIV per feedwater line: The [8] hour Completion 3

Time is reasonable to close the MFIV or its bypass valve, which includes performing a controlled unit shutdown to MODE 2.

7 day The [72] hour Completion Time takes into account the redundancy 3 afforded by the remaining OPERABLE valves, and the low probability of an event occurring during this time period that would require isolation of the MFW flow paths.

B.1 If more than one MFIV or [MFIV] bypass valve in the same flow path cannot be restored to OPERABLE status, then there may be no redundant system to operate automatically and perform the required safety function. Although the containment can be isolated with the failure of two valves in parallel in the same flow path, the double failure can be an indication of a common mode failure in the valves of this flow path, and as such is treated the same as a loss of the isolation capability of this 3 flow path. Under these conditions, valves in each flow path must be restored to OPERABLE status, closed, or the flow path isolated within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This action returns the system to the condition where at least one valve in each flow path is performing the required safety function.

The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Completion Time is reasonable to close the MFIV or its bypass valve, or otherwise isolate the affected flow path.

Inoperable MFIVs and [MFIV] bypass valves that cannot be restored to OPERABLE status within the Completion Time, but are closed or isolated, must be verified on a periodic basis that they are closed or isolated. This is necessary to ensure that the assumptions in the safety analysis remain valid. The 7 day Completion Time is reasonable, based on engineering judgment, in view of valve status indications available in the control room, and other administrative controls to ensure that these valves are closed or isolated.

CEOG STS B 3.7.3-3 Rev. 3.1, 12/01/05 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 75 of 485

Attachment 1, Volume 10, Rev. 0, Page 76 of 485 MFIVs [and [MFIV] Bypass Valves] 2 B 3.7.3 BASES ACTIONS (continued) B 3

C.1 and [C.2]

If the MFIVs and their bypass valves cannot be restored to OPERABLE 1 status, closed, or isolated in the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months [, 2 and in MODE 4 within [12] hours]. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE SR 3.7.3.1 REQUIREMENTS 2

within the limit given in This SR ensures the verification of each MFIV [and [MFIV] bypass valve]

Reference 2 and is within that is [7] seconds. The MFIV isolation time is assumed in the accident and TSTF-containment analyses. This Surveillance is normally performed upon SR 491-A 6 This SR also verifies the valve closure time is returning the unit to operation following a refueling outage. The MFIVs in accordance with the should not be tested at power since even a part stroke exercise increases Inservice Testing Program.

the risk of a valve closure with the unit generating power. As these valves are not tested at power, they are exempt from the ASME Code TSTF-(Ref. 2) requirements during operation in MODES 1 and 2. 491-A 3

The Frequency is in accordance with the Inservice Testing Program.

prior to MODE 3 during SR 3.7.3.2 This SR verifies that each MFIV [and [MFIV] bypass valve] can close on 2 an actual or simulated actuation signal. This Surveillance is normally performed upon returning the plant to operation following a refueling 6 outage.

The Frequency for this SR is every [18] months. The [18] month Frequency for testing is based on the refueling cycle. Operating TSTF-INSERT 1 experience has shown that these components usually pass the 425-A Surveillance when performed at the [18] month Frequency. Therefore, this Frequency is acceptable from a reliability standpoint.

Licensee Controlled Specifications.

U REFERENCES 1. FSAR, Section [10.4.7]. 1

2. Technical Requirements Manual TSTF-425-A 3 2. ASME Code for Operation and Maintenance of Nuclear Power Plants.

CEOG STS B 3.7.3-4 Rev. 3.1, 12/01/05 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 76 of 485

Attachment 1, Volume 10, Rev. 0, Page 77 of 485 B 3.7.3 TSTF-425-A INSERT 1 5

The Frequency is controlled under the Surveillance Frequency Control Program.

Reviewers Note ---------------------------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program 4

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

Insert Page 3.7.3-4 Attachment 1, Volume 10, Rev. 0, Page 77 of 485

Attachment 1, Volume 10, Rev. 0, Page 78 of 485 JUSTIFICATION FOR DEVIATIONS ITS 3.7.3 BASES, MAIN FEEDWATER ISOLATION VALVES (MFIVs)

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 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.

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

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

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

6. ISTS SR 3.7.3.1 and SR 3.7.3.2 Bases states, "This SR is normally performed upon returning the unit to operation following a refueling outage." This statement will be revised to read, "The SR is normally performed prior to MODE 3 during a refueling outage." This is acceptable because SCE normally performs this test in MODES 4, 5, or 6 and using the ISTS wording "following a refueling outage," would not be correct. This change is acceptable because SONGS Units 2 and 3 valves are pneumatic/hydraulic valves which do not require detailed testing at design operating temperature and pressure, but instead the testing relies on stroke time and detailed calculations/analysis.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 78 of 485

Attachment 1, Volume 10, Rev. 0, Page 79 of 485 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 10, Rev. 0, Page 79 of 485

Attachment 1, Volume 10, Rev. 0, Page 80 of 485 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.3, MAIN FEEDWATER ISOLATION VALVES (MFIVs)

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

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 80 of 485

Attachment 1, Volume 10, Rev. 0, Page 81 of 485 ATTACHMENT 4 ITS 3.7.4, ATMOSPHERIC DUMP VALVES (ADVs)

Attachment 1, Volume 10, Rev. 0, Page 81 of 485

, Volume 10, Rev. 0, Page 82 of 485 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 10, Rev. 0, Page 82 of 485

Attachment 1, Volume 10, Rev. 0, Page 83 of 485 ITS ADVs 3.7.4 A01 3.7 PLANT SYSTEMS 3.7.4 Atmospheric Dump Valves (ADVs) line LCO 3.7.4 LCO 3.7.4 One ADV per required Steam Generator (SG) shall be OPERABLE. M01 Applicability APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME line ACTION C A. One required ADV A.1 --------NOTE--------- M01 inoperable. LCO 3.0.4 is not A02 M02 C applicable.

C for reasons other than line Condition A. M01 Restore ADV to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

required D lines line ACTION D B. Two ADVs inoperable. B.1 Restore one ADV to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months A03 A02 M01 OPERABLE status.

for reasons other than D Condition B.

ACTIONS C. Backup nitrogen gas C.1 Restore backup 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months A and B supply system capacity nitrogen gas supply

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for one or system capacity for A02 more required ADV(s). one or more required ADV(s).

(continued)

A. One required ADV line inoperable due to A.1 Restore ADV line to OPERABLE 6 days backup nitrogen gas supply system capacity status.

8 hours.

B. Two required ADV lines inoperable due to B.1 Restore one ADV line to OPERABLE 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months backup nitrogen gas supply system capacity status.

8 hours.

SAN ONOFRE--UNIT 2 3.7-9 Amendment No. 127 Attachment 1, Volume 10, Rev. 0, Page 83 of 485

Attachment 1, Volume 10, Rev. 0, Page 84 of 485 ITS ADVs 3.7.4 A01 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION E D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion E Time of Condition A or AND E A02 B not met.

D.2 Be in MODE 4 without 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months reliance upon steam generator for heat removal.

E. Required Action and E.1 Declare the ADV Immediately associated completion inoperable. A02 time of Condition C not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY LA01 SR 3.7.4.1 SR 3.7.4.1 Verify the capacity of the backup nitrogen 7 days supply system.

is > 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months In accordance with the A04 Surveillance Frequency Control Program SR 3.7.4.2 SR 3.7.4.2 Verify one complete cycle of each ADV. In accordance with the Inservice Testing Program INSERT 1 M01 SAN ONOFRE--UNIT 2 3.7-10 Amendment No. 127 Attachment 1, Volume 10, Rev. 0, Page 84 of 485

Attachment 1, Volume 10, Rev. 0, Page 85 of 485 ITS 3.7.4 M01 INSERT 1 SR 3.7.4.3 SR 3.7.4.3 Verify one complete cycle of each ADV block valve. In accordance with the Surveillance Frequency Control Program 3.7-10 Attachment 1, Volume 10, Rev. 0, Page 85 of 485

Attachment 1, Volume 10, Rev. 0, Page 86 of 485 ITS ADVs 3.7.4 A01 3.7 PLANT SYSTEMS 3.7.4 Atmospheric Dump Valves (ADVs) line LCO 3.7.4 LCO 3.7.4 One ADV per required Steam Generator (SG) shall be OPERABLE. M01 Applicability APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME line ACTION C A. One required ADV A.1 --------NOTE--------- M01 inoperable. LCO 3.0.4 is not A02 M02 C applicable.

C ---------------------

for reasons other than line Condition A. M01 Restore ADV to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

required D lines line ACTION D B. Two ADVs inoperable. B.1 Restore one ADV to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months A03 A02 M01 OPERABLE status.

for reasons other than D

Condition B.

ACTIONS C. Backup nitrogen gas C.1 Restore backup 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months A and B supply system capacity nitrogen gas supply

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for one or system capacity for A02 more required ADV(s). one or more required ADV(s).

(continued)

A. One required ADV line inoperable due to A.1 Restore ADV line to OPERABLE 6 days backup nitrogen gas supply system capacity status.

8 hours.

B. Two required ADV lines inoperable due to B.1 Restore one ADV line to OPERABLE 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months backup nitrogen gas supply systems capacity status.

8 hours.

SAN ONOFRE--UNIT 3 3.7-9 Amendment No. 116 Attachment 1, Volume 10, Rev. 0, Page 86 of 485

Attachment 1, Volume 10, Rev. 0, Page 87 of 485 ITS ADVs 3.7.4 A01 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION E D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion E Time of Condition A or AND E A02 B not met.

D.2 Be in MODE 4 without 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months reliance upon steam generator for heat removal.

E. Required Action and E.1 Declare the ADV Immediately associated completion inoperable. A02 time of Condition C not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY LA01 SR 3.7.4.1 SR 3.7.4.1 Verify the capacity of the backup nitrogen 7 days supply system.

is > 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months In accordance with the A04 Surveillance Frequency Control Program SR 3.7.4.2 SR 3.7.4.2 Verify one complete cycle of each ADV. In accordance with the Inservice Testing Program M01 INSERT 1 SAN ONOFRE--UNIT 3 3.7-10 Amendment No. 116 Attachment 1, Volume 10, Rev. 0, Page 87 of 485

Attachment 1, Volume 10, Rev. 0, Page 88 of 485 ITS 3.7.4 M01 INSERT 1 SR 3.7.4.3 SR 3.7.4.3 Verify one complete cycle of each ADV block valve. In accordance with the Surveillance Frequency Control Program 3.7-10 Attachment 1, Volume 10, Rev. 0, Page 88 of 485

Attachment 1, Volume 10, Rev. 0, Page 89 of 485 DISCUSSION OF CHANGES ITS 3.7.4, ATMOSPHERIC DUMP VALVES (ADVs)

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 3.7.4 Required Action C.1 requires the backup nitrogen gas supply system capacity to be restored within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months when the capacity is 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for one or more ADVs. CTS 3.7.4 Required Action E.1 requires the ADV to be declared inoperable immediately when the Required Action and associated Completion Time of Condition C is not met. This requires CTS 3.7.4 Condition A to be entered when one of the ADVs is inoperable and CTS 3.7.4 Condition B to be entered when both ADVs are inoperable. Thus, the combination of the ACTIONS allows a 6 day Completion Time when one ADV is rendered inoperable and a 96 hour0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months Completion Time when two ADVs are rendered inoperable. ITS 3.7.4 contains two ACTIONS (ACTIONS A and B) written for one and two ADV lines inoperable, respectively, due to backup nitrogen gas supply system capacity 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . ITS 3.7.4 ACTIONS A and B Completion Times are 6 days and 92 hours0.00106 days 0.0256 hours 1.521164e-4 weeks 3.5006e-5 months for one ADV line and two ADV lines, respectively, inoperable. This changes the CTS by summing the Completion Times of CTS 3.7.4 ACTIONS C and E into ITS ACTIONS A and B without changing the total Completion Times prior to requiring a plant shutdown. Furthermore, due to this specific change, the remaining CTS ACTIONS have been renumbered, and the two Conditions for the specific ACTIONS when one or two ADVs are inoperable (CTS 3.7.4 ACTIONS A and B) have been modified to specifically exclude the nitrogen inoperability ACTIONS.

The Conditions for ITS 3.7.4 ACTIONS C and D include a statement that they are for reasons other than Condition A (for ITS 3.7.4 Condition C) and Conditions B (for ITS 3.7.4 Condition D).

The purpose of CTS 3.7.4 ACTION C and ACTION E is to ensure enough backup nitrogen is available to reach shutdown cooling entry conditions. The proposed change to the CTS revises the ACTIONS to more closely comply with ITS convention. This change is acceptable because the ACTIONS continue to require the backup nitrogen gas supply system to be restored to the ADV(s) while not changing the overall Completion Time to perform restoration prior to a plant shutdown. This change is designated as administrative because CTS ACTIONS are being revised without any technical alterations.

A03 CTS 3.7.4 Condition B states, "Two ADVs inoperable." ITS Condition D states, "Two required ADV lines inoperable for reasons other than Condition B." This changes the CTS by adding the word "required" in Condition B. The discussion of the renumbering of the Condition and the addition of the phrase "for reasons other than Condition B" is discussed in DOC A02 and the addition of the word "lines" is discussed in DOC M01.

San Onofre Unit 2 and 3 Page 1 of 6 Attachment 1, Volume 10, Rev. 0, Page 89 of 485

Attachment 1, Volume 10, Rev. 0, Page 90 of 485 DISCUSSION OF CHANGES ITS 3.7.4, ATMOSPHERIC DUMP VALVES (ADVs)

The word required is used in the ISTS when the unit has more installed components than the LCO requires. In this case, the MODE 4 Applicability may only require one ADV line, if only one SG is required to be OPERABLE. Thus, the term "required" is added to ensure that ITS 3.7.4 Condition D is only entered when both ADV lines are required and both are inoperable. When one ADV line is required and inoperable, ITS 3.7.4 Condition C is entered, consistent with the same requirement in CTS 3.7.4. Specifically, CTS 3.7.4 Condition A is entered when one "required" ADV is inoperable. That is, when the LCO only required one to be OPERABLE and that one is inoperable. This change is designated as administrative because the Condition is being clarified without being technically altered.

A04 CTS SR 3.7.4.1 verifies the capacity of the backup nitrogen gas supply system once per 7 days. ITS SR 3.7.4.1 requires verification that the capacity of the backup nitrogen supply system is "> 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ." This changes the CTS by adding the acceptance criterion to SR 3.7.4.1.

The purpose of SR 3.7.4.1 is to verify that there is enough backup nitrogen gas available to reach shutdown cooling conditions. The proposed change to the CTS adds acceptance criterion to SR 3.7.4.1. The addition of the > 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to the SR is a clarification. The addition of the criterion to the SR is administrative since the value already exists in CTS 3.7.4 Condition C. This change is acceptable because it only clarifies that the limit is 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and does not change the criterion. This change is designated as administrative because it adds clarification to the Surveillance Requirements without any technical alterations.

MORE RESTRICTIVE CHANGES M01 CTS LCO 3.7.4 requires one ADV per required steam generator to be OPERABLE. The CTS LCO does not specifically require the ADV block valves to be OPERABLE. Furthermore, the CTS does not include any Surveillance for the ADV block valves. ITS 3.7.4 LCO requires one ADV line per required steam generator to be OPERABLE. As stated in the ITS Bases, the ADV line consists of an ADV and the associated ADV block valve. Additionally, the CTS Conditions and Required Actions only reference an ADV being inoperable and having to be restored to OPERABLE status. ITS 3.7.4 references ADV lines and requires restoration of ADV lines. The ITS also includes SR 3.7.4.3 which requires verification of one complete cycle of each ADV block valve with a Frequency of in accordance with the Surveillance Frequency Control Program. This changes the CTS by requiring ADV lines to be OPERABLE, which essentially adds the ADV block valves to Technical Specifications. This also changes the CTS by adding an SR to verify one complete cycle of each ADV block valve.

The purpose of ITS 3.7.4 is to ensure a safety grade method for cooling the unit to shutdown cooling entry conditions is available should the preferred method, via the steam bypass system to the condenser, not be available. This change to CTS 3.7.4 ensures the ADV line is OPERABLE versus just the ADV. This change essentially adds the ADV block valves to Technical Specifications. The design must accommodate the single failure of one ADV to close on demand; San Onofre Unit 2 and 3 Page 2 of 6 Attachment 1, Volume 10, Rev. 0, Page 90 of 485

Attachment 1, Volume 10, Rev. 0, Page 91 of 485 DISCUSSION OF CHANGES ITS 3.7.4, ATMOSPHERIC DUMP VALVES (ADVs) therefore, the ADVs are equipped with block valves in the event an ADV spuriously opens, or fails to close during use. This change is acceptable because the ADV line is required to be OPERABLE to ensure the unit can be cooled to shutdown cooling entry conditions in the event of one of the steam generators becomes unavailable. SR 3.7.4.3 is being added to verify the function of the ADV block valve, which is to isolate a failed open ADV. Cycling the block valve closed and open demonstrates its capability to perform this function. This change is designated as more restrictive because additional requirements are being added to the ITS than are required by the CTS.

M02 CTS 3.7.4 Required Action A.1 requires an ADV to be restored to OPERABLE status and is modified by a Note which states LCO 3.0.4 is not applicable. ITS 3.7.4 Required Action C.1 requires the ADV line to be restored to OPERABLE status, but does not include the Note stating LCO 3.0.4 is not applicable. This changes the CTS by deleting the exception to LCO 3.0.4 from the Required Action.

The purpose of the Note to CTS 3.7.4 Required Action A.1 is to allow the unit to continue MODE changes during startup with one ADV inoperable. The proposed change to CTS 3.7.4 Required Action A.1 deletes the Note. Thus, if one ADV line (see DOC M01 for the change from ADV to ADV line) is inoperable, ITS 3.7.4 will only allow MODE changes using the allowances of ITS LCO 3.0.4.b, which requires performance of a risk assessment prior to changing MODES. This change adds the requirement to perform a risk assessment in order to enter the MODES of Applicability while the LCO is not met. Therefore, this change is considered acceptable. This change is designated as more restrictive because additional requirements are being added to the ITS than are required by 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 SR 3.7.4.1 requires verification of the backup nitrogen supply system capacity every 7 days. ITS SR 3.7.4.1 requires a similar Surveillance and specifies the periodic Frequency as "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified frequency for the SR and the Bases for the frequency to the Surveillance Frequency Control Program.

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

San Onofre Unit 2 and 3 Page 3 of 6 Attachment 1, Volume 10, Rev. 0, Page 91 of 485

Attachment 1, Volume 10, Rev. 0, Page 92 of 485 DISCUSSION OF CHANGES ITS 3.7.4, ATMOSPHERIC DUMP VALVES (ADVs)

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 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 San Onofre Unit 2 and 3 Page 4 of 6 Attachment 1, Volume 10, Rev. 0, Page 92 of 485

Attachment 1, Volume 10, Rev. 0, Page 93 of 485 DISCUSSION OF CHANGES ITS 3.7.4, ATMOSPHERIC DUMP VALVES (ADVs) 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.

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 San Onofre Unit 2 and 3 Page 5 of 6 Attachment 1, Volume 10, Rev. 0, Page 93 of 485

Attachment 1, Volume 10, Rev. 0, Page 94 of 485 DISCUSSION OF CHANGES ITS 3.7.4, ATMOSPHERIC DUMP VALVES (ADVs)

Standards or alternatives approved for use by the NRC, will continue to be met as described in the plant licensing basis (e.g., UFSAR, or Technical Specifications Bases). Also, the safety analysis acceptance criteria in the licensing basis (e.g., UFSAR, supporting analyses, etc.) are met with the proposed change.

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

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

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

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

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

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

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

LESS RESTRICTIVE CHANGES None San Onofre Unit 2 and 3 Page 6 of 6 Attachment 1, Volume 10, Rev. 0, Page 94 of 485

Attachment 1, Volume 10, Rev. 0, Page 95 of 485 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 10, Rev. 0, Page 95 of 485

Attachment 1, Volume 10, Rev. 0, Page 96 of 485 U2/U3 CTS ADVs 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Atmospheric Dump Valves (ADVs)

One per required steam generator 4

LCO 3.7.4 LCO 3.7.4 [Two] ADV lines shall be OPERABLE.

Applicability APPLICABILITY: MODES 1, 2, and 3,

[MODE 4 when steam generator is being relied upon for heat removal]. 2 ACTIONS INSERT 1 CONDITION REQUIRED ACTION COMPLETION TIME 1 3 C

ACTION A A. One required ADV line A.1 Restore ADV line to 7 days 3

for reasons inoperable. OPERABLE status. 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months other than C Condition A D 1 2 ACTION B B. Two or more [required] B.1 Restore all but one ADV 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 3 for reasons ADV lines inoperable. line to OPERABLE status.

other than D Condition B E ACTION D C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 3 associated Completion Time not met. E [ AND 2 C.2 Be in MODE 4 without [24] hours ] 3 2 reliance upon steam 18 generator for heat removal.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY INSERT 2 3

SR 3.7.4.2 SR 3.7.4.1 Verify one complete cycle of each ADV. [18] months 2

In accordance with the 5 Inservice Testing Program CEOG STS 3.7.4-1 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Amendment XXX Attachment 1, Volume 10, Rev. 0, Page 96 of 485

Attachment 1, Volume 10, Rev. 0, Page 97 of 485 U2/U3 CTS 3.7.4 3

INSERT 1 ACTION C A. One required ADV line A.1 Restore ADV line to 6 days inoperable due to backup OPERABLE status.

nitrogen gas supply system capacity 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

ACTION C B. Two required ADV lines B.1 Restore one ADV line to 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months inoperable due to backup OPERABLE status.

nitrogen gas supply system capacity 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

3 INSERT 2 SR 3.7.4.1 SR 3.7.4.1 Verify the capacity of the backup nitrogen supply In accordance system is > 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . with the Surveillance Frequency Control Program Insert Page 3.7.4-1 Attachment 1, Volume 10, Rev. 0, Page 97 of 485

Attachment 1, Volume 10, Rev. 0, Page 98 of 485 U2/U3 CTS ADVs 3.7.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY DOC M01 TSTF-SR 3.7.4.2 [ Verify one complete cycle of each ADV block [18] months ] 3 2 425-A 3 valve.

In accordance with the Surveillance Frequency Control Program CEOG STS 3.7.4-2 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Amendment XXX Attachment 1, Volume 10, Rev. 0, Page 98 of 485

Attachment 1, Volume 10, Rev. 0, Page 99 of 485 JUSTIFICATION FOR DEVIATIONS ITS 3.7.4, ATMOSPHERIC DUMP VALVES (ADVs)

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 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.

3. Two ACTIONS (ITS ACTION A and B) are being added to the ISTS for the backup nitrogen gas supply system when the system renders one and two ADV lines inoperable. The ACTIONS require restoration within 6 days when one required ADV line is rendered inoperable and 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months when two required ADV lines are inoperable due to an inoperable nitrogen gas supply system(s). The backup nitrogen gas supply system is required to be OPERABLE for the ADV line to be OPERABLE at SONGS. In addition an SR (SR 3.7.4.1) is being added to verify a backup nitrogen gas supply system with a capacity of > 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The Frequency of the SR is "In accordance with the Surveillance Frequency Control Program," consistent with TSTF-425 allowances. The addition of this new SR results in the renumbering of all subsequent SRs in the ISTS. Also, due to the addition of the new Conditions, "for reasons other than Condition A/B" is being added to the renumbered Conditions C and D.

4. The ISTS LCO 3.7.4 is being changed from "Two ADV lines shall be OPERABLE" to "One ADV line per required steam generator shall be OPERABLE." The ISTS is written such that there are two ADV lines per SG. SONGS has just one ADV line per SG and in MODE 4 SONGS could have one SG being utilized for heat removal. If the LCO required two ADV lines to be OPERABLE, SONGS would be in an ACTION unnecessarily. Therefore, the LCO was changed to require one ADV line per required steam generator. Also, due to SONGS just having one ADV line per steam generator, the Completion Time for ACTION A was changed from 7 days to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . These changes are also consistent with the SONGS Units 2 and 3 CTS.

5. The Frequency for ISTS SR 3.7.4.1 (verify one complete cycle of each ADV) is being changed from a bracketed value consistent with a units refueling outage to "In accordance with the Inservice Testing Program." The SONGS IST Program includes the ADV valve cycling requirements. This change is consistent with SONGS Units 2 and 3 CTS. In addition, due to this plant specific change, TSTF-425 which allows the Frequency to be relocated to the Surveillance Frequency Control Program, has not been adopted.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 99 of 485

Attachment 1, Volume 10, Rev. 0, Page 100 of 485 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 10, Rev. 0, Page 100 of 485

Attachment 1, Volume 10, Rev. 0, Page 101 of 485 ADVs B 3.7.4 B 3.7 PLANT SYSTEMS B 3.7.4 Atmospheric Dump Valves (ADVs)

BASES BACKGROUND The ADVs provide a safety grade method for cooling the unit to Shutdown Cooling (SDC) System entry conditions, should the preferred heat sink via the Steam Bypass System to the condenser not be available, as 1 2 U

discussed in the FSAR, Section [10.3] (Ref. 1). This is done in conjunction with the Auxiliary Feedwater System providing cooling water from the condensate storage tank (CST). The ADVs may also be required to meet the design cooldown rate during a normal cooldown when steam pressure drops too low for maintenance of a vacuum in the condenser to permit use of the Steam Bypass System.

Two Four ADV lines are provided. Each ADV line consists of one ADV and an 5 associated block valve. Two ADV lines per steam generator are required to meet single failure assumptions following an event rendering one 1 steam generator unavailable for Reactor Coolant System (RCS) heat removal.

The ADVs are provided with upstream block valves to permit their being tested at power, and to provide an alternate means of isolation. The ADVs are equipped with pneumatic controllers to permit control of the cooldown rate.

The ADVs are usually provided with a pressurized gas supply of bottled 1 stored in accumulators nitrogen that, on a loss of pressure in the normal instrument air supply, automatically supplies nitrogen to operate the ADVs. The nitrogen supply is sized to provide sufficient pressurized gas to operate the ADVs for the time required for RCS cooldown to the SDC System entry conditions.

A description of the ADVs is found in Reference 1. The ADVs are OPERABLE with only a DC power source available. In addition, hand wheels are provided for local manual operation.

APPLICABLE The design basis of the ADVs is established by the capability to cool the SAFETY unit to SDC System entry conditions. A cooldown rate of 75°F per hour ANALYSES is obtainable by one or both steam generators. This design is adequate to cool the unit to SDC System entry conditions with only one ADV and one steam generator, utilizing the cooling water supply available in the CST. 1 s

CEOG STS B 3.7.4-1 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 101 of 485

Attachment 1, Volume 10, Rev. 0, Page 102 of 485 ADVs B 3.7.4 BASES APPLICABLE SAFETY ANALYSES (continued)

U In the accident analysis presented in the FSAR, the ADVs are assumed 1 to be used by the operator to cool down the unit to SDC System entry conditions for accidents accompanied by a loss of offsite power. Prior to the operator action, the main steam safety valves (MSSVs) are used to maintain steam generator pressure and temperature at the MSSV setpoint. This is typically 30 minutes following the initiation of an event.

(This may be less for a steam generator tube rupture (SGTR) event.) The limiting events are those that render one steam generator unavailable for RCS heat removal, with a coincident loss of offsite power; this results from a turbine trip and the single failure of one ADV on the unaffected 1 steam generator. Typical initiating events falling into this category are a main steam line break upstream of the main steam isolation valves, a feedwater line break, and an SGTR event (although the ADVs on the affected steam generator may still be available following a SGTR event).

The design must accommodate the single failure of one ADV to open on 1

demand; thus, each steam generator must have at least two ADVs. The ADVs are equipped with block valves in the event an ADV spuriously opens, or fails to close during use.

The ADVs satisfy Criterion 3 of 10 CFR 50.36(c)(2)(ii).

is 5 2

LCO One [Two] ADV lines are required to be OPERABLE on each steam generator to ensure that at least one ADV is OPERABLE to conduct a unit cooldown following an event in which one steam generator becomes unavailable, 1 accompanied by a single active failure of one ADV line on the unaffected steam generator. The block valves must be OPERABLE to isolate a failed open ADV. A closed block valve does not render it or its ADV line inoperable if operator action time to open the block valve is supported in the accident analysis.

Failure to meet the LCO can result in the inability to cool the unit to SDC System entry conditions following an event in which the condenser is unavailable for use with the Steam Bypass System.

, and has an associated backup nitrogen gas supply system with a An ADV is considered OPERABLE when it is capable of providing a capacity of > 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months controlled relief of the main steam flow, and is capable of fully opening 1 and closing on demand.

CEOG STS B 3.7.4-2 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 102 of 485

Attachment 1, Volume 10, Rev. 0, Page 103 of 485 ADVs B 3.7.4 BASES APPLICABILITY In MODES 1, 2, and 3, [and in MODE 4, when steam generator is being 2 relied upon for heat removal,] the ADVs are required to be OPERABLE.

MSLB, FWLB, or are s 1 INSERT 1 In MODES 5 and 6, an SGTR is not a credible event.

C 3 ACTIONS A.1 With one required ADV line inoperable, action must be taken to restore 3 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months the OPERABLE status within 7 days. The 7 day Completion Time takes 1

for reasons other than into account the redundant capability afforded by the remaining backup nitrogen gas supply system capacity OPERABLE ADV lines, and a nonsafety grade backup in the Steam 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , Bypass System and MSSVs.

D 3 B.1 With [two] or more [required] ADV lines inoperable, action must be taken 2 3

to restore [one] of the ADV lines to OPERABLE status. As the block valve can be closed to isolate an ADV, some repairs may be possible with the unit at power. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable to repair inoperable ADV lines, based on the availability of the Steam Bypass System and MSSVs, and the low probability of an event occurring during this period that requires the ADV lines.

E C.1 and C.2 3 If the ADV lines cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4, without reliance upon 18 2 the steam generator for heat removal, within [24] hours. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly INSERT 2 manner and without challenging unit systems.

3 SURVEILLANCE SR 3.7.4.1 2 REQUIREMENTS To perform a controlled cooldown of the RCS, the ADVs must be able to be opened and throttled through their full range. This SR ensures the ADVs are tested through a full control cycle at least once per fuel cycle.

Performance of inservice testing or use of an ADV during a unit cooldown may satisfy this requirement. Operating experience has shown that these 1 components usually pass the SR when performed at the [18] month Frequency. Therefore, the Frequency is acceptable from a reliability 3 standpoint.

, "In accordance with the IST Program,"

CEOG STS B 3.7.4-3 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 103 of 485

Attachment 1, Volume 10, Rev. 0, Page 104 of 485 B 3.7.4 3

INSERT 1 A.1 and B.1 If backup nitrogen gas supply system capacity for one or more required ADV lines is less than or equal to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , action should be taken to restore nitrogen gas supply system capacity in 6 days if one ADV line is rendered inoperable and 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months if two ADV lines are rendered inoperable. The backup nitrogen capacity is controlled to a minimum accumulator pressure of 1018 psig (1060 psig including total loop uncertainty (Ref. 2)). This pressure represents enough backup nitrogen gas system capacity for each ADV to have up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of pneumatic operation. This time period is consistent and conservative relative to the SONGS Units 2 and 3 emergency operating instructions.

The Completion Times are based on operating experience and on the fact that the normal operating instrument air supply system is still available.

3 INSERT 2 SR 3.7.4.1 This SR ensures there is sufficient backup nitrogen to reach shutdown cooling following a Small Break Loss of Coolant Accident (SBLOCA) or natural circulation cooldown. A minimum accumulator pressure of 1018 psig (1060 psig including total loop uncertainty (Ref. 2)) is used to ensure sufficient backup nitrogen capacity. This pressure includes allowances for seven days worth of leakage and uncertainty in the nitrogen consumption rates and subsequent 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months of operation.

The Frequency is controlled under the Surveillance Frequency Control Program.

Insert Page B 3.7.4-3 Attachment 1, Volume 10, Rev. 0, Page 104 of 485

Attachment 1, Volume 10, Rev. 0, Page 105 of 485 ADVs B 3.7.4 BASES SURVEILLANCE REQUIREMENTS (continued) 2 3

[ SR 3.7.4.2 3 The function of the ADV block valve is to isolate a failed open ADV.

Cycling the block valve closed and open demonstrates its capability to 1

perform this function. Performance of inservice testing or use of the block valve during unit cooldown may satisfy this requirement. Operating TSTF-experience has shown that these components usually pass the SR when 425-A INSERT 3 performed at the [18] month Frequency. Therefore, the Frequency is acceptable from a reliability standpoint. ] 2 U

REFERENCES 1. FSAR, Section [10.3]. 1 2 1

2. Calculation J-ABB-031, "ADV Nitrogen Supply Pressure Indicator Uncertainty."

CEOG STS B 3.7.4-4 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 105 of 485

Attachment 1, Volume 10, Rev. 0, Page 106 of 485 B 3.7.4 TSTF-425-A INSERT 3 The Frequency is controlled under the Surveillance Frequency Control Program. 6

Reviewers Note ---------------------------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program 4

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

Insert Page B 3.7.4-4 Attachment 1, Volume 10, Rev. 0, Page 106 of 485

Attachment 1, Volume 10, Rev. 0, Page 107 of 485 JUSTIFICATION FOR DEVIATIONS ITS 3.7.4 BASES, ATMOSPHERIC DUMP VALVES (ADVs)

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 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.

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

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

5. SONGS Units 2 and 3 each have two ADV lines, one per SG.

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

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 107 of 485

Attachment 1, Volume 10, Rev. 0, Page 108 of 485 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 10, Rev. 0, Page 108 of 485

Attachment 1, Volume 10, Rev. 0, Page 109 of 485 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.4, ATMOSPHERIC DUMP VALVES (ADVs)

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

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 109 of 485

Attachment 1, Volume 10, Rev. 0, Page 110 of 485 ATTACHMENT 5 ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM Attachment 1, Volume 10, Rev. 0, Page 110 of 485

, Volume 10, Rev. 0, Page 111 of 485 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 10, Rev. 0, Page 111 of 485

Attachment 1, Volume 10, Rev. 0, Page 112 of 485 ITS AFW System A01 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5 Three AFW trains shall be OPERABLE.

LCO 3.7.5

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

1. Only one AFW train, which includes a motor driven pump, LCO 3.7.5 is required to be OPERABLE in MODE 4.

Notes 1 and 2 2. The steam driven AFW pump is OPERABLE when running and controlled manually to support plant start-ups, plant shut-downs, and AFW pump and valve testing.

APPLICABILITY: MODES 1, 2, and 3, Applicability MODE 4 when steam generator is relied upon for heat removal.

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

ACTIONS LCO 3.0.4.b is not applicable. A02 CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One steam supply to A.1 Restore affected 7 days turbine driven AFW equipment to OPERABLE A03 pump inoperable. status. AND Turbine driven AFW train inoperable OR due to one inoperable steam supply. 10 days from

NOTE----------- discovery of L01 Only applicable if failure to meet MODE 2 has not been the LCO entered following refueling One turbine driven AFW pump inoperable in MODE 3 following refueling.

ACTION B B. One AFW train B.1 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable for reasons Restore AFW train to A03 other than Condition A OPERABLE status. AND in MODE 1, 2, or 3.

10 days from discovery of L01 failure to meet the LCO C. Two AFW trains with C.1 Restore one AFW train 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months two motor driven pumps to OPERABLE status.

inoperable in MODES 1, M01 2, or 3.

(continued)

SAN ONOFRE--UNIT 2 3.7-11 Amendment No. 223 Attachment 1, Volume 10, Rev. 0, Page 112 of 485

Attachment 1, Volume 10, Rev. 0, Page 113 of 485 A01 ITS AFW System 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME the steam supply to the turbine driven M01 ACTION C D. Two AFW trains with one motor driven pump D.1 Restore one AFW train to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and steam driven pump OPERABLE status.

C inoperable in MODES 1, C M02 2, or 3.

INSERT 1 INSERT 2 ACTION D E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months M01 associated Completion D

D Time of Conditions A, B, C, or D not met. AND or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months INSERT 3 E.2 Be in MODE 4. M01 M02 D

ACTION E F. Three AFW trains F.1 --------NOTE--------- M01 inoperable in MODE 1, LCO 3.0.3 and all other E 2, or 3. LCO Required Actions E

requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to Immediately restore one AFW train to OPERABLE status.

(continued)

SAN ONOFRE--UNIT 2 3.7-12 Amendment No. 127 Attachment 1, Volume 10, Rev. 0, Page 113 of 485

Attachment 1, Volume 10, Rev. 0, Page 114 of 485 M02 INSERT 1 Turbine driven AFW train inoperable due to an inoperable steam supply.

AND One motor driven AFW train inoperable.

M02 INSERT 2 OR C.2 Restore the motor driven 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AFW train to OPERABLE status.

M01 INSERT 3 OR Two AFW trains inoperable in MODE 1, 2, or 3 for reasons other than Condition C.

Insert Page 3.7-12 Attachment 1, Volume 10, Rev. 0, Page 114 of 485

Attachment 1, Volume 10, Rev. 0, Page 115 of 485 A01 ITS AFW System 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION F G. Required AFW train G.1 --------NOTE--------- M01 inoperable in MODE 4. LCO 3.0.3 and all F other LCO Required F

Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to Immediately restore one AFW train to OPERABLE status.

OR G.2 Verify two Loops of Immediately decay heat OPERABLE A04 in accordance with LCO 3.4.6.

NA H. --------NOTE--------- H.1 Close the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Testing pursuant to valve or its block Technical valve.

Specification 3.3.5 or 3.3.6 does not AND constitute entry into L02 this condition. H.2 Enter the appropriate Immediately

ACTIONS (A, B, C, D, upon completion F, or G) if there is of ACTION H.1 An automatic valve in a loss of the flow any flow path path(s).

incapable of closing upon receipt of a Main Steam Isolation signal.

SAN ONOFRE--UNIT 2 3.7-13 Amendment No. 127 Attachment 1, Volume 10, Rev. 0, Page 115 of 485

Attachment 1, Volume 10, Rev. 0, Page 116 of 485 ITS AFW System A01 3.7.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 SR 3.7.5.1 Verify each AFW manual, power operated, and 31 days LA01 automatic valve in each water flow path and in both steam supply flow paths to the In accordance with the steam turbine driven pump, that is not Surveillance Frequency locked, sealed, or otherwise secured in Control Program position, is in the correct position.

SR 3.7.5.2 SR 3.7.5.2 -------------------NOTE--------------------

Not required to be performed for the turbine driven AFW pump until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after reaching 800 psig in the steam generators.

Verify the developed head of each AFW pump In accordance at the flow test point is greater than or with the equal to the required developed head. Inservice Testing Program SR 3.7.5.3 SR 3.7.5.3 -------------------NOTE--------------------

Not required to be performed for the 2. Not required to be met 1.

turbine driven AFW pump until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in MODE 4 when steam after reaching 800 psig in the steam generator is relied upon generators. for heat removal. A05 that is not locked, sealed, or otherwise Verify each AFW automatic valve actuates to 24 months L03 LA01 secured in position the correct position on an actual or simulated actuation signal, except valves In accordance with the HV-8200 and HV-8201. Surveillance Frequency Control Program (continued)

SAN ONOFRE--UNIT 2 3.7-14 Amendment No. 147, 191 Attachment 1, Volume 10, Rev. 0, Page 116 of 485

Attachment 1, Volume 10, Rev. 0, Page 117 of 485 A01 ITS AFW System 3.7.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.5.4 SR 3.7.5.4 -------------------NOTE-------------------- 24 months Not required to be performed for the LA01

1. turbine driven AFW pump until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after reaching 800 psig in the steam In accordance with the

2. Not required to be met generators. Surveillance Frequency A05 in MODE 4 when steam ------------------------------------------- Control Program generator is relied upon for heat removal. Verify each AFW pump starts automatically on an actual or simulated actuation signal.

A05 when in MODE 1, 2, or 3 SR 3.7.5.5 SR 3.7.5.5 Verify the proper alignment of the required Prior to AFW flow paths by verifying flow from the entering MODE 2 condensate storage tank to each steam whenever unit generator. has been in , MODE MODE 5 or 6 for A06

> 30 days

, or defueled for a cumulative period of SAN ONOFRE--UNIT 2 3.7-15 Amendment No. 127, 147 Attachment 1, Volume 10, Rev. 0, Page 117 of 485

Attachment 1, Volume 10, Rev. 0, Page 118 of 485 ITS AFW System A01 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5 Three AFW trains shall be OPERABLE.

LCO 3.7.5

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

1. Only one AFW train, which includes a motor driven pump, LCO 3.7.5 is required to be OPERABLE in MODE 4.

Notes 1 and 2 2. The steam driven AFW pump is OPERABLE when running and controlled manually to support plant start-ups, plant shut-downs, and AFW pump and valve testing.

APPLICABILITY: MODES 1, 2, and 3, Applicability MODE 4 when steam generator is relied upon for heat removal.

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

ACTIONS LCO 3.0.4.b is not applicable. A02 CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One steam supply to A.1 Restore affected 7 days turbine driven AFW pump equipment to OPERABLE A03 inoperable. status. AND Turbine driven AFW train inoperable OR due to one inoperable steam supply. 10 days from

NOTE----------- discovery of L01 Only applicable if failure to meet MODE 2 has not been the LCO entered following refueling One turbine driven AFW pump inoperable in MODE 3 following refueling.

ACTION B B. One AFW train B.1 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable for reasons Restore AFW train to A03 other than Condition A OPERABLE status. AND in MODE 1, 2, or 3.

10 days from discovery of L01 failure to meet the LCO C. Two AFW trains with C.1 Restore one AFW train to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months two motor driven pumps OPERABLE status.

inoperable in MODES 1, M01 2, or 3.

(continued)

SAN ONOFRE--UNIT 3 3.7-11 Amendment No. 216 Attachment 1, Volume 10, Rev. 0, Page 118 of 485

Attachment 1, Volume 10, Rev. 0, Page 119 of 485 A01 ITS AFW System 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION C D. Two AFW trains with the steam supply to the turbine driven M01 one motor driven pump D.1 Restore one AFW train to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and steam driven pump OPERABLE status.

C inoperable in MODES 1, C M02 2, or 3.

INSERT 1 INSERT 2 ACTION D E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months M01 associated Completion D

D Time of Conditions A, B, C, or D not met. AND or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months M01 INSERT 3 E.2 Be in MODE 4.

M02 D

ACTION E F. Three AFW trains F.1 --------NOTE--------- M01 inoperable in MODE 1, LCO 3.0.3 and all other E 2, or 3. LCO Required Actions E

requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to Immediately restore one AFW train to OPERABLE status.

(continued)

SAN ONOFRE--UNIT 3 3.7-12 Amendment No. 116 Attachment 1, Volume 10, Rev. 0, Page 119 of 485

Attachment 1, Volume 10, Rev. 0, Page 120 of 485 M02 INSERT 1 Turbine driven AFW train inoperable due to an inoperable steam supply.

AND One motor driven AFW train inoperable.

M02 INSERT 2 OR C.2 Restore the motor driven 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AFW train to OPERABLE status.

M01 INSERT 3 OR Two AFW trains inoperable in MODE 1, 2, or 3 for reasons other than Condition C.

Insert Page 3.7-12 Attachment 1, Volume 10, Rev. 0, Page 120 of 485

Attachment 1, Volume 10, Rev. 0, Page 121 of 485 A01 ITS AFW System 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION F G. Required AFW train G.1 --------NOTE---------

M01 inoperable in MODE 4. LCO 3.0.3 and all other F LCO Required Actions F

requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to restore one AFW train to Immediately OPERABLE status.

OR G.2 Verify two Loops of decay heat OPERABLE in Immediately accordance with LCO A04 3.4.6.

H. ---------NOTE-------- H.1 Close the affected valve 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months NA - or its block valve.

Testing pursuant to Technical AND Specification 3.3.5 or 3.3.6 does not H.2 Enter the appropriate constitute entry into ACTIONS (A, B, C, D, F, Immediately L02 this condition. or G) if there is a loss upon completion

of the flow path(s). of ACTION H.1 An automatic valve in any flow path incapable of closing upon receipt of a Main Steam Isolation signal.

SAN ONOFRE--UNIT 3 3.7-13 Amendment No. 116 Attachment 1, Volume 10, Rev. 0, Page 121 of 485

Attachment 1, Volume 10, Rev. 0, Page 122 of 485 ITS AFW System A01 3.7.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 SR 3.7.5.1 Verify each AFW manual, power operated, and 31 days LA01 automatic valve in each water flow path and in both steam supply flow paths to the In accordance with the steam turbine driven pump, that is not Surveillance Frequency locked, sealed, or otherwise secured in Control Program position, is in the correct position.

SR 3.7.5.2 SR 3.7.5.2 -------------------NOTE--------------------

Not required to be performed for the turbine driven AFW pump until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after reaching 800 psig in the steam generators.

Verify the developed head of each AFW pump In accordance at the flow test point is greater than or with the equal to the required developed head. Inservice Testing Program SR 3.7.5.3 SR 3.7.5.3 -------------------NOTE--------------------

Not required to be performed for the 2. Not required to be met 1.

turbine driven AFW pump until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in MODE 4 when steam after reaching 800 psig in the steam generator is relied upon generators. for heat removal. A05 that is not locked, sealed, or otherwise Verify each AFW automatic valve actuates to 24 months L03 LA01 secured in position the correct position on an actual or simulated actuation signal, except valves In accordance with the HV-8200 and HV-8201. Surveillance Frequency Control Program (continued)

SAN ONOFRE--UNIT 3 3.7-14 Amendment No. 139, 182 Attachment 1, Volume 10, Rev. 0, Page 122 of 485

Attachment 1, Volume 10, Rev. 0, Page 123 of 485 A01 ITS AFW System 3.7.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.5.4 SR 3.7.5.4 -------------------NOTE-------------------- 24 months Not required to be performed for the LA01

1. turbine driven AFW pump until 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after reaching 800 psig in the steam In accordance with the

2. Not required to be met generators. Surveillance Frequency A05 in MODE 4 when steam ------------------------------------------- Control Program generator is relied upon for heat removal. Verify each AFW pump starts automatically on an actual or simulated actuation signal.

A05 when in MODE 1, 2, or 3 SR 3.7.5.5 SR 3.7.5.5 Verify the proper alignment of the required Prior to AFW flow paths by verifying flow from the entering MODE 2 condensate storage tank to each steam whenever unit

, MODE generator. has been in MODE 5 or 6 for A06

> 30 days

, or defueled for a cumulative period of SAN ONOFRE--UNIT 3 3.7-15 Amendment No. 116, 139 Attachment 1, Volume 10, Rev. 0, Page 123 of 485

Attachment 1, Volume 10, Rev. 0, Page 124 of 485 DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM 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 ITS 3.7.5 ACTIONS include a Note that states LCO 3.0.4.b is not applicable.

CTS 3.7.5 does not include this Note. This changes the CTS by including the ACTIONS Note excluding the use of LCO 3.0.4.b.

This change is consistent with TSTF-359. The purpose of the ITS 3.7.5 ACTIONS Note is to prohibit entry into the Applicability of LCO 3.7.5 with an inoperable AFW train(s). Currently, CTS 3.7.5 and LCO 3.0.4 preclude entering MODE 4 when steam generator is relied upon for heat removal and an AFW train is inoperable. However, CTS 3.0.4 has been modified as described in the Discussion for Changes for ITS Section 3.0. ITS LCO 3.0.4 allows entry into a MODE or other specified condition in the Applicability under certain conditions when a Technical Specification required component is inoperable. ITS LCO 3.0.4.b allows entry into a MODE or other specified condition in the Applicability of a Specification if a risk assessment is performed and determines it is acceptable to enter the Applicability, and appropriate risk management actions are established. This addition of this Note (LCO 3.0.4.b is not applicable) is acceptable because there is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable AFW train(s),

and therefore the provisions of LCO 3.0.4.b should not be applied in this circumstance. The change is acceptable because CTS 3.7.5 and LCO 3.0.4 do not currently allow this option (i.e., MODES changes are not allowed while in the ACTIONS of this Specification). This change is considered administrative because it does not result in technical changes to the CTS.

A03 CTS 3.7.5 Condition A (first Condition) states, "One steam supply to turbine driven AFW pump inoperable." CTS 3.7.5 Condition B states, "One AFW train inoperable for reasons other than Condition A in MODE 1, 2, or 3." ITS 3.7.5 Condition A (first Condition) states, "Turbine driven AFW train inoperable due to an inoperable steam supply." ITS 3.7.5 Condition B states, "One AFW train inoperable in MODE 1, 2, or 3 for reasons other than Condition A." This changes the CTS by rewording the Conditions.

The changes to CTS 3.7.5 Conditions A and B are acceptable because they do not technically change the intent of the CTS Conditions. The intent of Condition A still focuses on an inoperable steam supply and the change to Condition B is consistent with TSTF-412. These changes are designated as administrative because CTS 3.7.5 Conditions A and B are reworded without technically changing the intent.

San Onofre Unit 2 and 3 Page 1 of 9 Attachment 1, Volume 10, Rev. 0, Page 124 of 485

Attachment 1, Volume 10, Rev. 0, Page 125 of 485 DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM A04 CTS 3.7.5 ACTION G provides the requirements when the required AFW train is inoperable in MODE 4. The Required Actions require action to be initiated to restore one AFW train to OPERABLE status (CTS 3.7.5 Required Action G.1) or to verify two loops of decay heat OPERABLE in accordance with LCO 3.4.6 (CTS 3.7.5 Required Action G.2). ITS 3.7.5 ACTION G is for a similar Condition, but only requires initiation of action to restore one AFW train to OPERABLE status; the second Required Action is not included in the ITS. This changes the CTS by deleting the requirement in CTS 3.7.5 to verify two loops of decay heat OPERABLE in accordance with LCO 3.4.6 when the required AFW train is inoperable in MODE 4.

The purpose of ITS 3.7.5 ACTION G is to ensure appropriate action is taken to ensure a method of decay heat removal is available in MODE 4. The proposed change deletes the Required Action that requires verification that two loops of decay heat removal are OPERABLE in accordance with LCO 3.4.6 in MODE 4.

Specifically requiring LCO 3.4.6 to be verified in the ACTIONS of LCO 3.7.5 in MODE 4 is not necessary. LCO 3.4.6 requirements are required to be complied with in MODE 4 as required by the TS 3.4.6 Applicability. Furthermore, if the CTS 3.4.6 LCO requirements are met using two shutdown cooling subsystems, then the CTS 3.7.5 MODE 4 requirement is not applicable anymore. Therefore, since exiting the Applicability is always an option, it does not need to be specified as a Required Action. This change is acceptable because a redundant requirement, which is essentially a cross-reference, is being deleted. This change is designated as administrative because the redundant information being deleted will not technically change the intent of the TS.

A05 CTS SR 3.7.5.3 requires verification each AFW automatic valve actuates to the correct position on an actual or simulated signal, except valves HV-8200 and HV-8201. CTS SR 3.7.5.4 requires verification each AFW pump starts automatically on an actual or simulated actuation signal. The Applicability for CTS 3.7.5 is MODES 1, 2, and 3, and MODE 4 when the steam generator is relied upon for heat removal. ITS SR 3.7.5.3 and SR 3.7.5.4 require similar Surveillances; however, the SRs are modified by a Note which states the SRs are not required to be met in MODE 4 when steam generator is relied upon for heat removal. Additionally, ITS SR 3.7.5.4 contains the wording, "when in MODES 1, 2, and 3." which makes the SR only required in MODES 1, 2, and 3.

This changes the CTS by adding a Note which modifies the SR to clarify the Applicability and adds additional wording to SR 3.7.5.4.

The purpose of the two SRs is to ensure the valves and pump actuate, as required. However, CTS 3.3.5, which provides the instrumentation requirements, does not include MODE 4. Specifically, Table 3.3.5-1 Functions 4 (Main Steam Isolation Signal), 6 (Emergency Feedwater Actuation Signal SG #1, and 7 (Emergency Feedwater Actuation Signal SG #2) are only required to be OPERABLE in MODES 1, 2, and 3. Thus, the SRs are actually not required to be met, since the signals are not required to be OPERABLE in MODE 4.

Therefore, this clarification is acceptable and considered administrative since it is matching the system SR's Applicability to the actual signal's Applicability.

A06 CTS SR 3.7.5.5 requires verifying the proper alignment of the required flow paths by verifying flow from the condensate storage tank to each steam generator prior San Onofre Unit 2 and 3 Page 2 of 9 Attachment 1, Volume 10, Rev. 0, Page 125 of 485

Attachment 1, Volume 10, Rev. 0, Page 126 of 485 DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM to entering MODE 2 whenever the unit has been in MODE 5 or 6 for > 30 days.

ITS SR 3.7.5.5 requires the same surveillance, but the Frequency is being changed to prior to entering MODE 2 whenever the unit has been in MODE 5, MODE 6, "or defueled for a cumulative period of" > 30 days. This changes the CTS by adding clarifying wording to the SR.

The purpose of ITS SR 3.7.5.5 is to ensure the AFW is properly aligned prior to entering MODE 2 whenever the unit has been in an extended shutdown. The addition of clarifying wording "defueled for a cumulative period of" is acceptable because an extended shutdown also includes when the unit is defueled. The change is designated as administrative, because clarifying information is being added to the SR without technically changing the intent.

MORE RESTRICTIVE CHANGES M01 CTS 3.7.5 ACTION C is for the Condition when two AFW trains with two motor driven pumps are inoperable in MODES 1, 2, or 3 and requires restoration of one AFW train to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . ITS 3.7.5 ACTION D provides the requirements for the same condition, and requires the unit to be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by deleting the 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months restoration time when two motor driven AFW trains are inoperable and requiring the unit to shutdown. As a result of the deletion of CTS 3.7.5 ACTION C, the subsequent ACTIONS have been renumbered as part of this change.

The purpose of ITS 3.7.5 ACTION D is to limit the time two AFW trains can be concurrently inoperable other than the Condition provided in ITS 3.7.5 ACTION C. CTS 3.7.5 ACTION C allows 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months to restore one motor driven AFW pump to OPERABLE status when both are inoperable. ITS 3.7.5 ACTION D requires the unit to be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when two motor driven AFW pumps are inoperable. The proposed change is acceptable since it appropriately limits the time the unit can continue to operate with both motor driven AFW pumps inoperable concurrently. This change is designated as more restrictive since less time is provided to restore inoperable components in the ITS than is provided in the CTS.

M02 CTS 3.7.5 ACTION D is for the Condition when two AFW trains with one motor driven pump and the steam driven pump are inoperable in MODES 1, 2, or 3.

The Required Action requires the restoration of one AFW train to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . ITS 3.7.5 ACTION C provides the requirements for a similar condition, but limits the reason for the steam driven AFW pump being inoperable to an inoperable steam supply. The Required Action requires restoration of the steam supply to the turbine driven train to OPERABLE status or restoration of the motor driven AFW train to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

If the steam driven pump is inoperable for any other reason other than one steam supply to the pump being inoperable along with one motor driven pump inoperable, ITS 3.7.5 ACTION D requires the unit to be in MODE 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by decreasing the Completion Time when the steam driven AFW pump is inoperable for any reason other than one steam supply to the pump being inoperable concurrent with an inoperable motor driven AFW pump, from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to requiring the unit to shutdown.

San Onofre Unit 2 and 3 Page 3 of 9 Attachment 1, Volume 10, Rev. 0, Page 126 of 485

Attachment 1, Volume 10, Rev. 0, Page 127 of 485 DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM The purpose of ITS 3.7.5 ACTION C is to limit the time one steam supply to the steam driven AFW pump is inoperable, concurrently with one motor driven AFW pump inoperable, to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . CTS 3.7.5 ACTION D allows time (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) to restore the steam driven AFW pump (inoperable for any reason) or the motor driven AFW pump to OPERABLE status. ITS 3.7.5 ACTION D requires the unit to be shutdown when two AFW pumps are inoperable for reasons other than Condition C (other than when one steam supply to the steam driven AFW pump and one motor driven AFW pump are inoperable). The proposed change is acceptable since it appropriately limits the time the unit can continue to operate when the steam driven AFW pump is inoperable other than when one steam supply is inoperable concurrent with one motor driven AFW pump. This change is designated as more restrictive since less time is provided to restore inoperable components in the ITS than is provided 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 SR 3.7.5.1 requires verification that each AFW manual, power operated, and automatic valve in each water flow path and in both steam supply flow paths to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position every 31 days. CTS SR 3.7.5.3 requires verification that each AFW automatic valve actuates to the correct position on an actual or simulated actuation signal, except valves HV-8200 and HV-8201 every 24 months. CTS 3.7.5.4 requires verification that each AFW pump starts automatically on an actual or simulated actuation signal once per 24 months. ITS 3.7.5 requires similar Surveillances (ISTS SRs 3.7.5.1, 3.7.5.3, and 3.7.5.4, respectively) and specifies the periodic Frequency as "In accordance with the Surveillance Frequency Control Program."

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

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

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program; San Onofre Unit 2 and 3 Page 4 of 9 Attachment 1, Volume 10, Rev. 0, Page 127 of 485

Attachment 1, Volume 10, Rev. 0, Page 128 of 485 DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM

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 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.

San Onofre Unit 2 and 3 Page 5 of 9 Attachment 1, Volume 10, Rev. 0, Page 128 of 485

Attachment 1, Volume 10, Rev. 0, Page 129 of 485 DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM

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

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

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

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

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

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

3. The proposed change maintains sufficient safety margins.

Conformance with this principle is assured since SSC design, operation, testing methods and acceptance criteria specified in the Codes and Standards or alternatives approved for use by the NRC, will continue to be met as described in the plant licensing basis (e.g., UFSAR, or Technical Specifications Bases). Also, the safety analysis acceptance criteria in the San Onofre Unit 2 and 3 Page 6 of 9 Attachment 1, Volume 10, Rev. 0, Page 129 of 485

Attachment 1, Volume 10, Rev. 0, Page 130 of 485 DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM 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 L01 (Category 3 - Relaxation of Completion Time) CTS 3.7.5 ACTION A and ACTION B contain a second Completion time to restore the affected AFW equipment within 10 days from discovery of failure to meet the LCO. ITS 3.7.5 ACTION A and ACTION B which provide the actions for the same Conditions of CTS 3.7.5 ACTIONS A and B, do not contain this second Completion Time. This changes the CTS by deleting the second Completion Time that requires restoration of the affected inoperable AFW equipment within 10 days from discovery of failure to meet the LCO.

The second Completion Time was included in the SONGS TS and originally in the ISTS for certain Required Actions to establish a limit on the maximum time allowed for any combination of Conditions that result in a single continuous failure to meet the LCO. These Completion Times (henceforth referred to as second Completion Times) are joined by an AND logical connector to the Condition-specific Completion Time and state X days from discovery of failure to meet the LCO (where X varies by specification). The intent of the second Completion Time was to preclude entry into and out of the ACTIONS for an indefinite period of time without meeting the LCO by providing a limit on the amount of time that the LCO could not be met for various combinations of Conditions.

This change was initiated (in accordance with NUREG-1432 as revised by TSTF-439) due to the problems the second Completion Time presents when Completion Times are extended by risk informed methodology by complicating the presentation of the ITS and complicating the implementation of risk-informed San Onofre Unit 2 and 3 Page 7 of 9 Attachment 1, Volume 10, Rev. 0, Page 130 of 485

Attachment 1, Volume 10, Rev. 0, Page 131 of 485 DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM Completion Times. Deleting the second Completion Time is acceptable due to other regulatory requirements that are now present that were not present when the second Completion Time was proposed.

The two regulatory programs in place which provide a strong disincentive to continued operation with concurrent multiple inoperabilities of the type the second Completion Times were designed to prevent are the Maintenance Rule,10 CFR 50.65, and the Reactor Oversight Process, NEI 99-02.

The Maintenance Rule requires each licensee to monitor the performance of System, Structures, and Components (SSCs) against licensee-established goals to ensure that the SSCs are capable of fulfilling their intended functions. This Rule also considers all inoperable risk-significant equipment and not just those in the same system or those governed by the same LCO. The risk assessments performed prior to maintenance activities are governed by Regulatory Guide 1.182. Any issues associated with equipment inoperability is monitored by the NRC Resident Inspector and reported in the Corrective Action Program.

The Reactor Oversight Process: NEI 99-02, Regulatory Assessment Performance Indicator Guideline, describes the tracking and reporting of performance indicators to support the NRCs Reactor Oversight Process (ROP).

The NEI document is endorsed by RIS 2001-11, Voluntary Submission of Performance Indicator Data. NEI 99-02, Section 2.2, describes the Mitigating Systems Cornerstone. NEI 99-02 specifically addresses emergency AC Sources (which encompasses the AC Sources and Distribution System LCOs), and the Auxiliary feedwater system. Extended unavailability of these systems due to multiple entries into the ACTIONS would affect the NRCs evaluation of the licensees performance under the ROP.

In addition to these regulatory programs, a requirement is being added to TS Section 1.3 which requires the licensees to have administrative controls to limit the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls should consider plant risk and shall limit the maximum contiguous time of failing to meet the LCO. This Technical Specification requirement, when considered with the regulatory processes discussed above, provide an equivalent or superior level of plant safety without the unnecessary complication of the Technical Specifications by second Completion Times on some Specifications.

This change is considered less restrictive because it results in the relaxation of the Completion Time by eliminating the requirement for the train to be restored 10 days from discovery of failure to meet the LCO.

L02 (Category 4 - Relaxation of Required Action) CTS 3.7.5 ACTION H is for the condition when an automatic valve in any flow path is incapable of closing upon receipt of a Main Steam Isolation signal. CTS 3.7.5 Required Action H.1 requires closure of the affected valve or its block valve within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and Required Action H.2 requires entry in the appropriate Actions (A, B, C, D, E, or G) if there is a loss of the flow path(s) immediately upon completion of ACTION H.1. ITS 3.7.5 does not contain this ACTION. This changes the CTS by deleting this specific ACTION.

San Onofre Unit 2 and 3 Page 8 of 9 Attachment 1, Volume 10, Rev. 0, Page 131 of 485

Attachment 1, Volume 10, Rev. 0, Page 132 of 485 DISCUSSION OF CHANGES ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM The purpose of CTS 3.7.5 ACTION H is to provide ACTIONS when automatic valves in the AFW flow path are not capable of closing upon receipt of a main steam isolation signal (MSIS). This change essentially deletes the CTS 3.7.5 Required Action (H.1) to close the affected valve or its block valve when automatic valves in the AFW flow path is are not capable of closing upon receipt of a main steam isolation signal within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The ITS will still require the ACTION(S) for the affected flow path to be entered. ITS SR 3.7.5.3 is the Surveillance Requirement that verifies the automatic valves actuate on the associated signals. Thus, if they do not, then the associated AFW trains would be declared inoperable. This change is acceptable because the associated ACTION Completion Times are appropriate based on operating experience and the probability of an event occurring while trying to restore the affected equipment. This change is designated as less restrictive because the requirement to close affected valves that will not close on an MSIS is being deleted and the ACTIONS for the affected flow paths will be entered.

L03 (Category 5 - Deletion of a Surveillance Requirement) CTS SR 3.7.5.3 requires verifying that each AFW automatic valve actuates to the correct position on an actual or simulated actuation signal, except valves HV-8200 and HV-8201. ITS SR 3.7.5.3 requires verifying that each AFW automatic valve "that is not locked, sealed, or otherwise secured in position" actuates to the correct position on an actual or simulated actuation signal, except valves HV-8200 and HV-8201. This changes the CTS by excluding those AFW valves that are locked, sealed or otherwise secured in position from the verification.

The purpose of CTS 3.7.5.3 is to provide assurance that if an event occurred that required the AFW valves to be in their correct position, then those requiring automatic actuation would actuate to their correct position. This change is acceptable because the deleted Surveillance Requirement is not necessary to verify that the equipment used to meet the LCO can perform its required functions. The verification of valves that are aligned and secured into the required safety position is unnecessary. Valves secured in the safety position will satisfy the safety analyses assumptions for the mitigation of analyzed accidents. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

San Onofre Unit 2 and 3 Page 9 of 9 Attachment 1, Volume 10, Rev. 0, Page 132 of 485

Attachment 1, Volume 10, Rev. 0, Page 133 of 485 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 10, Rev. 0, Page 133 of 485

Attachment 1, Volume 10, Rev. 0, Page 134 of 485 U2/U3 CTS AFW System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5 LCO 3.7.5 [Three] AFW trains shall be OPERABLE. 2 S

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

LCO 3.7.5 Only one AFW train, which includes a motor driven pump, is required to 3 Notes 1 and 2 1.

be OPERABLE in MODE 4.

2. The turbine driven AFW pump is OPERABLE when running and controlled manually to support plant startups, plant shutdowns, and AFW pump and valve testing.

Applicability APPLICABILITY: MODES 1, 2, and 3,

[MODE 4 when steam generator is relied upon for heat removal]. 2 ACTIONS

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

NA LCO 3.0.4.b is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. [ One steam supply to A.1 Restore affected equipment 7 days ] 2 TSTF-turbine driven AFW to OPERABLE status. 412-A pump inoperable.

Turbine driven AFW train OR inoperable due to one inoperable steam supply.

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

Only applicable if MODE 2 has not been entered following refueling.

One turbine driven AFW pump inoperable in MODE 3 following refueling.

1 CEOG STS 3.7.5-1 Rev. 3.1, 12/01/05 San Onofre -- Draft Amendment XXX Attachment 1, Volume 10, Rev. 0, Page 134 of 485

Attachment 1, Volume 10, Rev. 0, Page 135 of 485 U2/U3 CTS AFW System 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION B B. One AFW train B.1 Restore AFW train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in MODE 1, inoperable [for reasons OPERABLE status.

2, or 3 other than Condition A]

in MODE 1, 2, or 3.

INSERT 1 ACTION E C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months D associated Completion D TSTF-Time of Condition A AND 412-A

[or B] not met.

, B, or C C.2 Be in MODE 4. [18] hours

[ OR D 12 2

[Two] AFW trains inoperable in MODE 1, 2, or 3. ] for reasons other than Condition C ACTION F D. [ [Three] AFW trains D.1 ---------------NOTE-------------- TSTF- 2 412-A E inoperable in MODE 1, LCO 3.0.3 and all other E

2, or 3. LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to restore one Immediately ] 2 AFW train to OPERABLE status.

1 CEOG STS 3.7.5-2 Rev. 3.1, 12/01/05 San Onofre -- Draft Amendment XXX Attachment 1, Volume 10, Rev. 0, Page 135 of 485

Attachment 1, Volume 10, Rev. 0, Page 136 of 485 U2/U3 CTS 3.7.5 TSTF-412-A INSERT 1 ACTION C C. Turbine driven AFW C.1 Restore the steam supply [24 or 48] hours 2 train inoperable due to to the turbine driven train to an inoperable steam OPERABLE status.

supply.

OR AND 2

C.2 Restore the motor driven [24 or 48] hours One motor driven AFW AFW train to OPERABLE train inoperable. status.

Insert Page 3.7.5-2 Attachment 1, Volume 10, Rev. 0, Page 136 of 485

Attachment 1, Volume 10, Rev. 0, Page 137 of 485 U2/U3 CTS AFW System 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION G E. Required AFW train E.1 ---------------NOTE-------------- TSTF-412-A inoperable in MODE 4. F LCO 3.0.3 and all other F

LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to restore one Immediately AFW train to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY TSTF-SR 3.7.5.1 SR 3.7.5.1 Verify each AFW manual, power operated, and 31 days 425-A automatic valve in each water flow path and in both steam supply flow paths to the steam turbine driven In accordance with the Surveillance Frequency Control Program pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.

SR 3.7.5.2 SR 3.7.5.2 -------------------------------NOTE------------------------------

72 Not required to be performed for the turbine driven AFW pump until [24] hours after reaching [800] psig 2 in the steam generators.

Verify the developed head of each AFW pump at the In accordance flow test point is greater than or equal to the with the Inservice required developed head. Testing Program 1

CEOG STS 3.7.5-3 Rev. 3.1, 12/01/05 San Onofre -- Draft Amendment XXX Attachment 1, Volume 10, Rev. 0, Page 137 of 485

Attachment 1, Volume 10, Rev. 0, Page 138 of 485 U2/U3 CTS AFW System 3.7.5 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.5.3 SR 3.7.5.3 ------------------------------NOTES-----------------------------

72

1. Not required to be performed for the turbine driven AFW pump until [24] hours after reaching 2

[800] psig in the steam generators.

2. Not required to be met in MODE 4 when steam generator is relied upon for heat removal.

TSTF-Verify each AFW automatic valve that is not locked, [18] months 425-A sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated In accordance with the Surveillance actuation signal. Frequency Control Program

, except valves HV-8200 and HV-8201 1 SR 3.7.5.4 SR 3.7.5.4 ------------------------------NOTES-----------------------------

72

1. Not required to be performed for the turbine driven AFW pump until [24] hours after reaching 2

[800] psig in the steam generators.

2. Not required to be met in MODE 4 when steam generator is relied upon for heat removal.

TSTF-Verify each AFW pump starts automatically on an [18] months 425-A actual or simulated actuation signal when in In accordance with the Surveillance MODE 1, 2, or 3. Frequency Control Program SR 3.7.5.5 SR 3.7.5.5 Verify the proper alignment of the required AFW Prior to entering flow paths by verifying flow from the condensate MODE 2 storage tank to each steam generator. whenever unit has been in MODE 5, MODE 6, or defueled for a cumulative period of > 30 days 1

CEOG STS 3.7.5-4 Rev. 3.1, 12/01/05 San Onofre -- Draft Amendment XXX Attachment 1, Volume 10, Rev. 0, Page 138 of 485

Attachment 1, Volume 10, Rev. 0, Page 139 of 485 JUSTIFICATION FOR DEVIATIONS ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM

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 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.

3. ISTS LCO 3.7.5 is being changed to add a second Note which states, "The turbine driven AFW pump is OPERABLE when running and controlled manually to support plant start-ups, plant shut-downs, and AFW pump and valve testing." This change is consistent with SONGS Units 2 and 3 TS Amendments 164 and 155, respectively, approved by the NRC in the Safety Evaluation dated 2/23/2000.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 139 of 485

Attachment 1, Volume 10, Rev. 0, Page 140 of 485 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 10, Rev. 0, Page 140 of 485

Attachment 1, Volume 10, Rev. 0, Page 141 of 485 AFW System B 3.7.5 B 3.7 PLANT SYSTEMS B 3.7.5 Auxiliary Feedwater (AFW) System BASES BACKGROUND The AFW System automatically supplies feedwater to the steam generators to remove decay heat from the Reactor Coolant System upon the loss of normal feedwater supply. The AFW pumps take suction through separate and independent suction lines from the condensate storage tank (CST) (LCO 3.7.6, "Condensate Storage Tank (CST)") and pump to the steam generator secondary side via separate and inside independent connections to the main feedwater (MFW) piping outside 1 containment. The steam generators function as a heat sink for core decay heat. The heat load is dissipated by releasing steam to the atmosphere from the steam generators via the main steam safety valves (MSSVs) (LCO 3.7.1, "Main Steam Safety Valves (MSSVs)") or atmospheric dump valves (ADVs) (LCO 3.7.4, "Atmospheric Dump Valves (ADVs)"). If the main condenser is available, steam may be released via the steam bypass valves and recirculated to the CST.

The AFW System consists of [two] motor driven AFW pumps and one 2 steam turbine driven pump configured into three trains. Each motor driven pump provides 100% of AFW flow capacity; the turbine driven pump provides 100% of the required capacity to the steam generators as assumed in the accident analysis. The pumps are equipped with independent recirculation lines to prevent pump operation against a closed system.

Each motor driven AFW pump is powered from an independent Class 1E power supply, and feeds one steam generator, although each pump has 1

the capability to be realigned from the control room to feed the other by local operation steam generator.

One pump at full flow is sufficient to remove decay heat and cool the unit to Shutdown Cooling (SDC) System entry conditions.

The steam turbine driven AFW pump receives steam from either main steam header upstream of the main steam isolation valve (MSIV). Each of the steam feed lines will supply 100% of the requirements of the turbine driven AFW pump. The turbine driven AFW pump supplies a common header capable of feeding both steam generators, with DC powered control valves actuated to the appropriate steam generator by the Emergency Feedwater Actuation System (EFAS).

The AFW System supplies feedwater to the steam generators during normal unit startup, shutdown, and hot standby conditions.

CEOG STS B 3.7.5-1 Rev. 3.1, 12/01/05 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 141 of 485

Attachment 1, Volume 10, Rev. 0, Page 142 of 485 AFW System B 3.7.5 BASES BACKGROUND (continued)

The AFW System is designed to supply sufficient water to the steam generator(s) to remove decay heat with steam generator pressure at the setpoint of the MSSVs. Subsequently, the AFW System supplies sufficient water to cool the unit to SDC entry conditions, and steam is released through the ADVs.

5 The AFW System actuates automatically on low steam generator level by the EFAS as described in LCO 3.3.2, "Engineered Safety Feature 5 Actuation System (ESFAS) Instrumentation." The EFAS logic is designed to feed either or both steam generators with low levels, but will isolate the AFW System from a steam generator having a significantly lower steam pressure than the other steam generator. The EFAS automatically actuates the AFW turbine driven pump and associated DC operated valves and controls when required, to ensure an adequate feedwater supply to the steam generators. DC operated valves are provided for each AFW line to control the AFW flow to each steam generator.

U The AFW System is discussed in the FSAR, Section [10.4.9] (Ref. 1). 1 2 APPLICABLE The AFW System mitigates the consequences of any event with a loss of SAFETY normal feedwater.

ANALYSES The design basis of the AFW System is to supply water to the steam generator to remove decay heat and other residual heat, by delivering at least the minimum required flow rate to the steam generators at pressures corresponding to the lowest MSSV set pressure plus 3%.

The limiting Design Basis Accidents (DBAs) and transients for the AFW System are as follows:

a. Feedwater Line Break (FWLB) and

b. Loss of normal feedwater.

In addition, the minimum available AFW flow and system characteristics are serious considerations in the analysis of a small break loss of coolant accident.

CEOG STS B 3.7.5-2 Rev. 3.1, 12/01/05 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 142 of 485

Attachment 1, Volume 10, Rev. 0, Page 143 of 485 AFW System B 3.7.5 BASES APPLICABLE SAFETY ANALYSES (continued)

The AFW System design is such that it can perform its function following an FWLB between the MFW isolation valve and containment, combined with a loss of offsite power following turbine trip, and a single active failure of the steam turbine driven AFW pump. In such a case, the EFAS logic might not detect the affected steam generator if the backflow check valve to the affected MFW header worked properly. One motor driven 7

AFW pump would deliver to the broken MFW header at the pump runout flow until the problem was detected, and flow was terminated by the operator. Sufficient flow would be delivered to the intact steam generator by the redundant AFW pump.

The AFW System satisfies Criterion 3 of 10 CFR 50.36(c)(2)(ii).

LCO This LCO requires that [three] AFW trains be OPERABLE to ensure that 2 the AFW System will perform the design safety function to mitigate the consequences of accidents that could result in overpressurization of the reactor coolant pressure boundary. Three independent AFW pumps, in two diverse trains, ensure availability of residual heat removal capability for all events accompanied by a loss of offsite power and a single failure.

This is accomplished by powering two pumps from independent emergency buses. The third AFW pump is powered by a diverse means, steam driven turbine supplied with steam from a source not isolated by the closure of the MSIVs.

The AFW System is considered to be OPERABLE when the components and flow paths required to provide AFW flow to the steam generators are OPERABLE. This requires that the two motor driven AFW pumps be OPERABLE in two diverse paths, each supplying AFW to a separate steam generator. The turbine driven AFW pump shall be OPERABLE with redundant steam supplies from each of the two main steam lines upstream of the MSIVs and capable of supplying AFW flow to either of the two steam generators. The piping, valves, instrumentation, and controls in the required flow paths shall also be OPERABLE.

The LCO is modified by a Note indicating that only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.

This is because of reduced heat removal requirements, the short period of time in MODE 4 during which AFW is required, and the insufficient steam supply available in MODE 4 to power the turbine driven AFW pump. 3 INSERT 1 CEOG STS B 3.7.5-3 Rev. 3.1, 12/01/05 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 143 of 485

Attachment 1, Volume 10, Rev. 0, Page 144 of 485 3.7.5 3

INSERT 1 The LCO Note 2 indicating that the turbine driven AFW pump is OPERABLE when running and controlled manually to support plant startups, plant shutdowns, and AFW pump and valve testing is necessary because if a Main Steam Line Break (MSLB) occurs, causing MSIS initiation followed by EFAS initiation, while the turbine driven AFW pump is operating, the turbine driven AFW pump turbine can trip on overspeed. However, the best estimate is that by operating the turbine driven AFW Pump in manual, the cumulative core damage frequency CDF decreases by approximately 2E-10/yr. The value of 2E-10/yr is based on the assumption that the turbine driven AFW pump is operated in the manual mode approximately 500 minutes per year. This decrease in CDF is a result of the turbine driven AFW Pump being available for all other required uses while operating in manual.

Insert Page B 3.7.5-3 Attachment 1, Volume 10, Rev. 0, Page 144 of 485

Attachment 1, Volume 10, Rev. 0, Page 145 of 485 AFW System B 3.7.5 BASES APPLICABILITY In MODES 1, 2, and 3, the AFW System is required to be OPERABLE and to function in the event that the MFW is lost. In addition, the AFW System is required to supply enough makeup water to replace steam generator secondary inventory, lost as the unit cools to MODE 4 conditions.

In MODE 4, the AFW System may be used for heat removal via the steam generator.

In MODES 5 and 6, the steam generators are not normally used for decay heat removal, and the AFW System is not required.

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable AFW train. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an AFW train inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

2

[ A.1 If one of the two steam supplies to the turbine driven AFW pumps is TSTF-due to one inoperable inoperable, or if a turbine driven pump is inoperable while in MODE 3 for any 412-A steam supply reason immediately following refueling, action must be taken to restore the inoperable equipment to an OPERABLE status within 7 days. The 7 day Completion Time is reasonable based on the following reasons:

a. For the inoperability of a steam supply to the turbine driven AFW TSTF-due to one inoperable pump, the 7 day Completion Time is reasonable since there is a 412-A steam supply redundant steam supply line for the turbine driven pump.

and the turbine train is still capable of performing its specified function for most b. For the inoperability of a turbine driven AFW pump while in MODE 3 postulated events immediately subsequent to a refueling outage, the 7 day Completion Time is reasonable due to the minimal decay heat levels in this situation.

c. For both the inoperability of a steam supply line to the turbine driven TSTF-412-A due to one inoperable pump and an inoperable turbine driven AFW pump while in MODE 3 steam supply immediately following a refueling outage, the 7 day Completion Time is reasonable due to the availability of redundant OPERABLE motor driven AFW pumps; and due to the low probability of an event requiring the use of the turbine driven AFW pump.

CEOG STS B 3.7.5-4 Rev. 3.1, 12/01/05 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 145 of 485

Attachment 1, Volume 10, Rev. 0, Page 146 of 485 AFW System B 3.7.5 BASES ACTIONS (continued)

Condition A is modified by a Note which limits the applicability of the TSTF-for an inoperable Condition to when the unit has not entered MODE 2 following a refueling. 412-A turbine driven AFW pump in MODE 3 Condition A allows one AFW train to be inoperable for 7 days vice the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time in Condition B. This longer Completion Time is based on the reduced decay heat following refueling and prior to the reactor being critical. ] 2 B.1 With one of the required AFW trains (pump or flow path) inoperable, action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This Condition includes the loss of two steam supply lines to the turbine driven AFW pump. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable based on the redundant capabilities afforded by the AFW System, the time needed for repairs, and the low probability of a DBA event occurring during this period. Two AFW pumps and flow paths remain to supply feedwater to the steam generators.

INSERT 2 D

C.1 and C.2

, , C.1, or C.2 TSTF-412-A When either Required Action A.1 or B.1 cannot be completed within the required Completion Time, [or if two AFW trains are inoperable in for reasons other MODES 1, 2, and 3], the unit must be placed in a MODE in which the 2

than Condition C LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 within [18] hours.

12 The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

2 In MODE 4, with [two AFW trains inoperable in MODES 1, 2, and 3],

operation is allowed to continue because only one motor driven AFW pump is required in accordance with the Note that modifies the LCO.

Although it is not required, the unit may continue to cool down and start 1 the SDC.

System CEOG STS B 3.7.5-5 Rev. 3.1, 12/01/05 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 146 of 485

Attachment 1, Volume 10, Rev. 0, Page 147 of 485 3.7.5 INSERT 2 TSTF-412-A C.1 and C.2 With one of the required motor driven AFW trains (pump or flow path) inoperable and the turbine driven AFW train inoperable due to one inoperable steam supply, action must be taken to restore the affected equipment to OPERABLE status within [24][48] hours. Assuming no single 2 active failures when in this condition, the accident (a FWLB or MSLB) could result in the loss of the remaining steam supply to the turbine driven AFW pump due to the faulted SG. In this condition, the AFW system may no longer be able to meet the required flow to the SGs assumed in the safety analysis, [either due to the analysis requiring flow from two AFW pumps 2 or due to the remaining AFW pump having to feed a faulted SG].

REVIEWER'S NOTE--------------------------------------------------

Licensees should adopt the appropriate Completion Time based on their plant design. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is applicable to plants that can no longer meet the safety analysis requirement of 100% AFW flow to the SG(s) assuming no single active failure and a FLB or 4 MSLB resulting in the loss of the remaining steam supply to the turbine driven AFW pump. The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time is applicable to plants that can still meet the safety analysis requirement of 100% AFW flow to the SG(s) assuming no single active failure and a FLB or MSLB resulting in the loss of the remaining steam supply to the turbine driven AFW pump.

[The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable based on the remaining OPERABLE steam supply 2 to the turbine driven AFW pump, the availability of the remaining OPERABLE motor driven AFW pump, and the low probability of an event occurring that would require the inoperable steam 2 supply to be available for the turbine driven AFW pump.]

[The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time is reasonable based on the fact that the remaining motor driven AFW train is capable of providing 100% of the AFW flow requirements, and the low probability 2 of an event occurring that would challenge the AFW system.]

Insert Page B 3.7.5-5 Attachment 1, Volume 10, Rev. 0, Page 147 of 485

Attachment 1, Volume 10, Rev. 0, Page 148 of 485 AFW System B 3.7.5 BASES ACTIONS (continued)

E D.1 TSTF-E 412-A Required Action D.1 is modified by a Note indicating that all required MODE changes or power reductions are suspended until one AFW train is restored to OPERABLE status.

2 With all [three] AFW trains inoperable in MODES 1, 2, and 3, the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting a cooldown with nonsafety grade equipment. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore one AFW train to OPERABLE status. LCO 3.0.3 is not applicable, as it could force the unit into a less safe condition.

F E.1 TSTF-F 412-A Required Action E.1 is modified by a Note indicating that all required MODE changes or power reductions are suspended until one AFW train is restored to OPERABLE status.

With one AFW train inoperable, action must be taken to immediately restore the inoperable train to OPERABLE status or to immediately verify, by administrative means, the OPERABILITY of a second train. LCO 3.0.3 is not applicable, as it could force the unit into a less safe condition.

In MODE 4, either the reactor coolant pumps or the SDC loops can be used to provide forced circulation as discussed in LCO 3.4.6, "RCS Loops - MODE 4."

SURVEILLANCE SR 3.7.5.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the AFW water and steam supply flow paths provides assurance that the proper flow paths exist for AFW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulations; rather, it involves verification that those valves capable of potentially being mispositioned are in the correct position.

CEOG STS B 3.7.5-6 Rev. 3.1, 12/01/05 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 148 of 485

Attachment 1, Volume 10, Rev. 0, Page 149 of 485 AFW System B 3.7.5 BASES SURVEILLANCE REQUIREMENTS (continued)

The 31 day Frequency is based on engineering judgment, is consistent TSTF-INSERT 3 425-A with the procedural controls governing valve operation, and ensures correct valve positions.

SR 3.7.5.2 Verifying that each AFW pump's developed head at the flow test point is greater than or equal to the required developed head ensures that AFW pump performance has not degraded during the cycle. Flow and

/ANSI OM differential head are normal tests of pump performance required by the (Part 6) ASME Code (Ref. 2). Because it is undesirable to introduce cold AFW 1 into the steam generators while they are operating, this testing is performed on recirculation flow. This test confirms one point on the pump design curve and is indicative of overall performance. Such inservice tests confirm component OPERABILITY, trend performance, and detect

/ANSI OM incipient failures by indicating abnormal performance. Performance of (Part 6) inservice testing, discussed in the ASME Code (Ref. 2), at 3 month 1 intervals satisfies this requirement.

This SR is modified by a Note indicating that the SR should be deferred until suitable test conditions are established. This deferral is required because there is an insufficient steam pressure to perform the test.

SR 3.7.5.3 This SR ensures that AFW can be delivered to the appropriate steam or MSIS generator, in the event of any accident or transient that generates an EFAS signal, by demonstrating that each automatic valve in the flow path 1 actuates to its correct position on an actual or simulated actuation signal.

This Surveillance is not required for valves that are locked, sealed, or otherwise secured in the required position under administrative controls.

The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit outage and the TSTF-INSERT 3 potential for an unplanned transient if the Surveillance were performed 425-A with the reactor at power. The 18 month Frequency is acceptable, based on the design reliability and operating experience of the equipment.

This SR is modified by a Note indicating that the SR should be deferred until suitable test conditions have been established. This deferral is required because there is an insufficient steam pressure to perform the test.

CEOG STS B 3.7.5-7 Rev. 3.1, 12/01/05 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 149 of 485

Attachment 1, Volume 10, Rev. 0, Page 150 of 485 3.7.5 TSTF-425-A INSERT 3 The Frequency is controlled under the Surveillance Frequency Control Program. 6

Reviewers Note ---------------------------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program 4

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

Insert Page B 3.7.5-7 Attachment 1, Volume 10, Rev. 0, Page 150 of 485

Attachment 1, Volume 10, Rev. 0, Page 151 of 485 AFW System B 3.7.5 BASES SURVEILLANCE REQUIREMENTS (continued)

Also, this SR is modified by a Note that states the SR is not required to be met in MODE 4. In MODE 4, the required AFW train is already aligned and operating.

SR 3.7.5.4 This SR ensures that the AFW pumps will start in the event of any accident or transient that generates an EFAS signal by demonstrating that each AFW pump starts automatically on an actual or simulated actuation signal. The [18] month Frequency is based on the need to perform this Surveillance under the conditions that apply during a unit TSTF-INSERT 3 outage and the potential for an unplanned transient if the Surveillance 425-A were performed with the reactor at power. The 18 month Frequency is acceptable, based on the design reliability and operating experience of the equipment.

[ This SR is modified by two Notes. Note 1 indicates that the SR be deferred until suitable test conditions are established. This deferral is required because there is insufficient steam pressure to perform the test.

Note 2 states that the SR is not required to be met in MODE 4. [In 2 MODE 4, the required pump is already operating and the autostart function is not required.] [In MODE 4, the heat removal requirements would be less providing more time for operator action to manually start the required AFW pump.]

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

Some plants may not routinely use the AFW for heat removal in MODE 4. 4 The second justification is provided for plants that use a startup feedwater pump rather than AFW for startup and shutdown.

SR 3.7.5.5 This SR ensures that the AFW System is properly aligned by verifying the flow path to each steam generator prior to entering MODE 2 operation, after 30 days in any combination of MODE 5 or 6, or defueled.

OPERABILITY of AFW flow paths must be verified before sufficient core heat is generated that would require the operation of the AFW System during a subsequent shutdown. The Frequency is reasonable, based on engineering judgment, and other administrative controls to ensure that flow paths remain OPERABLE. To further ensure AFW System alignment, the OPERABILITY of the flow paths is verified following CEOG STS B 3.7.5-8 Rev. 3.1, 12/01/05 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 151 of 485

Attachment 1, Volume 10, Rev. 0, Page 152 of 485 3.7.5 TSTF-425-A INSERT 3 The Frequency is controlled under the Surveillance Frequency Control Program. 6

Reviewers Note ---------------------------------------------------

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

Insert Page B 3.7.5-8 Attachment 1, Volume 10, Rev. 0, Page 152 of 485

Attachment 1, Volume 10, Rev. 0, Page 153 of 485 AFW System B 3.7.5 BASES SURVEILLANCE REQUIREMENTS (continued) extended outages to determine that no misalignment of valves has is OPERABLE by occurred. This SR ensures that the flow path from the CST to the steam raising Steam Generator level by 2%

generators is properly aligned by requiring a verification of minimum flow 1

using AFW flow from capacity of 750 gpm at 1270 psi. (This SR is not required by those units the CST.

that use AFW for normal startup and shutdown.)

REFERENCES 1. FSAR, Section [10.4.9]. 1 2 U /ANSI OM (Part 6)

2. ASME Code for Operation and Maintenance of Nuclear Power 1 Plants.

CEOG STS B 3.7.5-9 Rev. 3.1, 12/01/05 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 10, Rev. 0, Page 153 of 485

Attachment 1, Volume 10, Rev. 0, Page 154 of 485 JUSTIFICATION FOR DEVIATIONS ITS 3.7.5 BASES, AUXILIARY FEEDWATER (AFW) SYSTEM

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 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.

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

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

5. Changes are made to be consistent with the SONGS ITS specific Specification number.

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

7. ISTS 3.7.5 Bases, ASA Section, contains a discussion on the possible failure of the EFAS logic to not detect a FWLB between the MFIV and containment if the backflow check valve to the affected MFW header worked properly. It goes on to state that one motor driven AFW pump would deliver flow out of the break at runout flow and the other AFW pump would deliver to the SG whose MFW header does not have the break. This requirement is not applicable to SONGS. The SONGS backflow check valve is inside containment with AFW flow entering the line downstream of the backflow check valve. This would preclude any AFW flow being delivered out a break between the MFIV and containment assuming the backflow check valve worked properly. Thus the scenario depicted in the ISTS Bases could not occur at SONGS if the backflow check valve worked properly. Therefore, this section of the ISTS Bases is being deleted for the SONGS ITS 3.7.5 Bases.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 154 of 485

Attachment 1, Volume 10, Rev. 0, Page 155 of 485 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 10, Rev. 0, Page 155 of 485

Attachment 1, Volume 10, Rev. 0, Page 156 of 485 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.7.5, AUXILIARY FEEDWATER (AFW) SYSTEM There are no specific No Significant Hazards Considerations for this Specification.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 10, Rev. 0, Page 156 of 485

Attachment 1, Volume 10, Rev. 0, Page 157 of 485 ATTACHMENT 6 ITS 3.7.6, CONDENSATE STORAGE TANKS (CSTs)

Attachment 1, Volume 10, Rev. 0, Page 157 of 485

, Volume 10, Rev. 0, Page 158 of 485 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 10, Rev. 0, Page 158 of 485

Attachment 1, Volume 10, Rev. 0, Page 159 of 485 A01 CST T-121 and T-120 A02 s 3.7.6 ITS 3.7 PLANT SYSTEMS s

3.7.6 Condensate Storage Tank (CST T-121 and T-120) A02 s

LCO 3.7.6, LCO 3.7.6 The CST T-121 contained volume shall be $ 144,000 gallons SR 3.7.6.1 and CST T-120 contained volume shall be $ 360,000 gallons. A02 Two OPERABLE Applicability APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME s

ACTION A A. CST T-121 or T-120 A.1 Verify OPERABILITY of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months contained volumes not backup water supply. A02 within limit. AND One or two inoperable Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND (s)

A.2 Restore CST T-121 and 7 days T-120 contained A02 volumes to within limit.

to OPERABLE status ACTION B B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 4 without 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months reliance on steam generator for heat removal.

SAN ONOFRE--UNIT 2 3.7-16 Amendment No. 127, 162 Attachment 1, Volume 10, Rev. 0, Page 159 of 485

Attachment 1, Volume 10, Rev. 0, Page 160 of 485 A01 CST T-121 and T-120 A02 s 3.7.6 ITS SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6.1 SR 3.7.6.1 Verify CST T-121 and T-120 contained 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months A02 LA01 volumes are within limit.

In accordance with the Surveillance Frequency is > 144,000 gal and CST T-120 Control Program contained volume is > 360,000 gal SAN ONOFRE--UNIT 2 3.7-17 Amendment No. 127 Attachment 1, Volume 10, Rev. 0, Page 160 of 485

Attachment 1, Volume 10, Rev. 0, Page 161 of 485 A01 CST T-121 and T-120 A02 s 3.7.6 ITS 3.7 PLANT SYSTEMS s

3.7.6 Condensate Storage Tank (CST T-121 and T-120) A02 s

LCO 3.7.6, LCO 3.7.6 The CST T-121 contained volume shall be $ 144,000 gallons SR 3.7.6.1 and CST T-120 contained volume shall be $ 360,000 gallons. A02 Two OPERABLE Applicability APPLICABILITY: MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME s

ACTION A A. CST T-121 or T-120 A.1 Verify OPERABILITY of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months contained volumes not backup water supply. A02 within limit. AND One or two inoperable Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND (s)

A.2 Restore CST T-121 and 7 days T-120 contained A02 volumes to within limit.

to OPERABLE status ACTION B B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 4 without 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months reliance on steam generator for heat removal.

SAN ONOFRE--UNIT 3 3.7-16 Amendment No. 116, 153 Attachment 1, Volume 10, Rev. 0, Page 161 of 485

Attachment 1, Volume 10, Rev. 0, Page 162 of 485 A01 CST T-121 and T-120 A02 s 3.7.6 ITS SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6.1 SR 3.7.6.1 Verify CST T-121 and T-120 contained 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months A02 LA01 volumes are within limit.

In accordance with the Surveillance Frequency is > 144,000 gal and CST T-120 Control Program contained volume is > 360,000 gal SAN ONOFRE--UNIT 3 3.7-17 Amendment No. 116 Attachment 1, Volume 10, Rev. 0, Page 162 of 485

Attachment 1, Volume 10, Rev. 0, Page 163 of 485 DISCUSSION OF CHANGES ITS 3.7.6, CONDENSATE STORAGE TANKS (CSTs)

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 3.7.6 title, header, and LCO statement contain the specific CST designators (T-120 and T-121). CTS LCO 3.7.6 includes the actual limits (in gallons) for the two CSTs. CTS 3.7.6 Condition A includes the two designators and specifies that either is "not within limit." CTS 3.7.6 Required Action A.2 requires restoration of the two CSTs to "within limit," and also includes the designators.

ITS 3.7.6 title, header, LCO, and ACTIONS do not list the specific CST designators and ACTION A uses the term "inoperable" and "OPERABLE status" in lieu of "within limits." Furthermore, ITS SR 3.7.6.1 includes the CST volume limits in lieu of LCO 3.7.6. This changes the CTS by deleting the specific CST designators from the title, header, LCO, and ACTIONS, rewords portions of ACTION A (Condition and Required Action A.2) and moves the limits from the LCO to the SR.

The purpose of CTS 3.7.6 is to ensure the CSTs contain sufficient cooling water to remove decay heat consistent with the accident analysis. This change deletes the specific CST designators, rewords CTS Condition A and Required Action A.2, and removes the limits from the LCO. These changes are acceptable because the CTS is not being technically altered. The CST designators are still defined in ITS SR 3.7.6.1 and the limits are also maintained in the ITS SR 3.7.6.1. Thus, the two CSTs are still required to meet the limits. Furthermore, the terms being changed are consistent with the terminology used in the ISTS. This change is designated as administrative because the changes do not technically affect the intent of the TS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None San Onofre Unit 2 and 3 Page 1 of 4 Attachment 1, Volume 10, Rev. 0, Page 163 of 485

Attachment 1, Volume 10, Rev. 0, Page 164 of 485 DISCUSSION OF CHANGES ITS 3.7.6, CONDENSATE STORAGE TANKS (CSTs)

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 3.7.6.1 requires verification that CST T-121 and T-120 contained volumes within limit every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . ITS 3.7.6.1 requires a similar Surveillance and specifies the periodic Frequency as "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified frequencies for the SRs and the Bases for the frequencies to the Surveillance Frequency Control Program.

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 2 of 4 Attachment 1, Volume 10, Rev. 0, Page 164 of 485

Attachment 1, Volume 10, Rev. 0, Page 165 of 485 DISCUSSION OF CHANGES ITS 3.7.6, CONDENSATE STORAGE TANKS (CSTs)