Text

Attachment 1, Volume 11, San Onofre Nuclear Generating Station - Improved Technical Specifications Conversion - ITS Section 3.8, Electrical Power Systems
	ML11251A105
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: ML11251A105 (437)
	v • d • e

Attachment 1, Volume 11, Rev. 0, Page 1 of 437 ATTACHMENT 1 VOLUME 11 SAN ONOFRE NUCLEAR GENERATING STATION IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.8 ELECTRICAL POWER SYSTEMS Attachment 1, Volume 11, Rev. 0, Page 1 of 437

Attachment 1, Volume 11, Rev. 0, Page 2 of 437 LIST OF ATTACHMENTS

1. ITS 3.8.1 - AC Sources - Operating

2. ITS 3.8.2 - AC Sources - Shutdown

3. ITS 3.8.3 - Diesel Fuel Oil, Lube Oil, and Starting Air

4. ITS 3.8.4 - DC Sources - Operating

5. ITS 3.8.5 - DC Sources - Shutdown

6. ITS 3.8.6 - Battery Parameters

7. ITS 3.8.7 - Inverters - Operating

8. ITS 3.8.8 - Inverters - Shutdown

9. ITS 3.8.9 - Distribution Systems - Operating

10. ITS 3.8.10 - Distribution Systems - Shutdown Attachment 1, Volume 11, Rev. 0, Page 2 of 437

, Volume 11, Rev. 0, Page 3 of 437 ATTACHMENT 1 ITS 3.8.1, AC SOURCES-OPERATING , Volume 11, Rev. 0, Page 3 of 437

, Volume 11, Rev. 0, Page 4 of 437 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 11, Rev. 0, Page 4 of 437

Attachment 1, Volume 11, Rev. 0, Page 5 of 437 ITS AC Sources Operating A01 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources Operating LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

LCO 3.8.1

a. Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System; and

b. Two diesel generators (DGs) each capable of supplying one train of the onsite Class 1E AC Electrical Power Distribution System.

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

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

LCO 3.0.4.b is not applicable to DGs.

A02 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One required offsite A.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months circuit inoperable. for required OPERABLE offsite circuit. AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months INSERT 1 thereafter AND M01 A.2 Restore required -----NOTE-------

offsite circuit to The Completion A07 OPERABLE status. Time may be extended to 10 days once per train prior to 7/01/2012 to perform maintenance.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND 17 days from discovery of L01 failure to meet LCO (continued)

SAN ONOFRE--UNIT 2 3.8-1 Amendment No. 224 Attachment 1, Volume 11, Rev. 0, Page 5 of 437

, Volume 11, Rev. 0, Page 6 of 437 3.8.1 M01 INSERT 1 AND A.2 Declare required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from feature(s) with no offsite discovery of no offsite power available power to one train inoperable when its concurrent with redundant required inoperability of feature(s) is inoperable. redundant required feature(s)

Insert Page 3.8-1 , Volume 11, Rev. 0, Page 6 of 437

Attachment 1, Volume 11, Rev. 0, Page 7 of 437 ITS AC Sources Operating A01 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION B B. One required DG B.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months A04 inoperable. for the OPERABLE required offsite AND circuits.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND B.2 Declare required 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from feature(s) supported discovery of by the inoperable DG Condition B inoperable when its concurrent with redundant required inoperability of feature(s) is redundant inoperable. required feature(s)

AND B.3.1 Determine OPERABLE DG 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is not inoperable due to common cause failure.

OR B.3.2 Perform SR 3.8.1.2 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for OPERABLE DG.

AND B.4 Restore required DG 14 days A04 to OPERABLE status.

AND 17 days from discovery of L01 failure to meet LCO (continued)

SAN ONOFRE--UNIT 2 3.8-2 Amendment No. 127141 Attachment 1, Volume 11, Rev. 0, Page 7 of 437

Attachment 1, Volume 11, Rev. 0, Page 8 of 437 ITS AC Sources Operating A01 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION C C. Two required offsite C.1 Declare required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from circuits inoperable. feature(s) inoperable discovery of when its redundant Condition C required feature(s) concurrent with is inoperable. inoperability of redundant required feature(s)

AND C.2 Restore one required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months offsite circuit to OPERABLE status.

ACTION D D. One required offsite ------------NOTE-------------

circuit inoperable. Enter applicable Conditions and Required Actions of AND LCO 3.8.9, "Distribution with no AC power Systems Operating," when source to any train One required DG Condition D is entered. A03 inoperable. ----------------------------- A04 D.1 Restore required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months offsite circuit to OPERABLE status.

OR D.2 Restore required DG 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months A04 to OPERABLE status.

ACTION E E. Two required DGs E.1 Restore one required 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months A04 inoperable. DG to OPERABLE status.

(continued)

SAN ONOFRE--UNIT 2 3.8-3 Amendment No. 127 Attachment 1, Volume 11, Rev. 0, Page 8 of 437

Attachment 1, Volume 11, Rev. 0, Page 9 of 437 ITS AC Sources Operating A01 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION F F. Required Action and F.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Associated Completion Time of Condition A, AND 4 12 B, C, D, or E not met.

F.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months L02 ACTION G G. Three or more required G.1 Enter LCO 3.0.3. Immediately AC sources inoperable.

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

LCO 3.0.4.a is not applicable when entering MODE 4.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 SR 3.8.1.1 -------------------NOTES-------------------

1. Bus 3A04 is required when unit crosstie breaker 3A0416 is used to LA01 provide a source of AC power.

2. Bus 3A06 is required when unit In accordance with the crosstie breaker 3A0603 is used to Surveillance Frequency Control Program provide a source of AC power.

Verify correct breaker alignment and power 7 days LA02 availability for each required offsite circuit.

(continued)

SAN ONOFRE--UNIT 2 3.8-4 Amendment No. 218 Attachment 1, Volume 11, Rev. 0, Page 9 of 437

Attachment 1, Volume 11, Rev. 0, Page 10 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.2 SR 3.8.1.2 -------------------NOTES-------------------

1. Performance of SR 3.8.1.7 satisfies LA03 this SR.

2. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

3. A modified DG start involving idling and gradual acceleration to rated speed may be used for this SR as recommended by the manufacturer. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met.

4. To ensure Operability of an AVR, it must have been aligned to the DG An automatic voltage regulator (AVR) is only required to be tested once per during the performance of SR 3.8.1.2 A05 two Surveillance intervals. and SR 3.8.1.3 within the last 60 days, plus any allowance per In accordance with the SR 3.0.2. Surveillance Frequency Control Program Verify each DG starts from standby conditions and achieves: As specified in LA02 Table 3.8.1-1

a. Steady state voltage $ 4161 V and

4576 V; and

b. Steady state frequency $ 59.7 Hz and

61.2 Hz.

(continued)

SAN ONOFRE--UNIT 2 3.8-5 Amendment No. 216 Attachment 1, Volume 11, Rev. 0, Page 10 of 437

Attachment 1, Volume 11, Rev. 0, Page 11 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.3 SR 3.8.1.3 -------------------NOTES-------------------

1. DG loadings may include gradual loading as recommended by the manufacturer.

2. Momentary transients outside the load range do not invalidate this test.

3. This Surveillance shall be conducted on only one DG at a time.

4. This SR shall be preceded by, and immediately follow without shutdown, a successful performance of SR 3.8.1.2 or SR 3.8.1.7.

5. To ensure Operability of an AVR, it must have been aligned to the DG An automatic voltage regulator (AVR) is only required to be tested once per during the performance of SR 3.8.1.2 A05 two Surveillance intervals. and SR 3.8.1.3 within the last 60 days, plus any allowance per SR 3.0.2.

Verify each DG is synchronized and loaded, As specified in LA02 and operates for $ 60 minutes at a load Table 3.8.1-1

$ 4450 kW and # 4700 kW.

SR 3.8.1.4 SR 3.8.1.4 Verify each day tank contains $ 31.5 inches 31 days LA08 LA02 of fuel oil. a fuel oil level > 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of DG operation at full load plus 10%

In accordance with the Surveillance Frequency Control Program SR 3.8.1.5 SR 3.8.1.5 Check for and remove accumulated water from 31 days each day tank. LA02 SR 3.8.1.6 SR 3.8.1.6 Verify the fuel oil transfer system 31 days LA02 operates to transfer fuel oil from storage tank to the day tank.

(continued)

SAN ONOFRE--UNIT 2 3.8-6 Amendment No. 211 Attachment 1, Volume 11, Rev. 0, Page 11 of 437

Attachment 1, Volume 11, Rev. 0, Page 12 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.7 SR 3.8.1.7 -------------------NOTES-------------------

1. All DG starts may be preceded by an engine prelube period.

2. Credit may be taken for unplanned 184 days A06 LA02 events that satisfy this SR.

Verify each DG starts from standby condition and:

a. In # 9.4 seconds, achieves voltage

$ 4161 V and frequency $ 59.7 Hz; In accordance with the Surveillance Frequency

b. Maintains steady state voltage Control Program

$ 4161 V and # 4576 V; and

c. Maintains steady state frequency

$ 59.7 Hz and # 61.2 Hz.

SR 3.8.1.8 SR 3.8.1.8 -------------------NOTE------------------

1. Credit may be taken for unplanned M03 This Surveillance shall not events that satisfy this SR.

normally be performed in MODE 1 or 2. However, this Surveillance may be 2. Testing to satisfy this SR shall 24 months LA02 performed to reestablish include actual automatic and manual OPERABILITY provided an transfer to at least one alternate assessment determines the safety of the plant is offsite circuit. The other alternate maintained or enhanced. offsite circuit may be verified by overlapping circuit tests.

Verify capability of automatic and manual transfer of AC power sources from the normal offsite circuit to each alternate required offsite circuit.

(continued)

SAN ONOFRE--UNIT 2 3.8-7 Amendment No. 216 Attachment 1, Volume 11, Rev. 0, Page 12 of 437

Attachment 1, Volume 11, Rev. 0, Page 13 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY S

SR 3.8.1.9 SR 3.8.1.9 -------------------NOTE-------------------

INSERT 2

1. Credit may be taken for unplanned M03 events that satisfy this SR.

M02 INSERT 3

2. To ensure Operability of an AVR, it 3 must have been aligned to the DG An automatic voltage regulator (AVR) is only during the performance of either SR 3.8.1.9, SR 3.8.1.10, or A05 required to be tested once each Surveillance interval SR 3.8.1.19 within the last 24 months, during the performance of plus any allowance per SR 3.0.2.

SR 3.8.1.9, SR 3.8.1.10, ------------------------------------------

or SR 3.8.1.19.

Verify each DG rejects a load greater than 24 months or equal to its associated single largest LA02 post-accident load, and:

a. Following load rejection, the frequency is # 66.75 Hz;

b. Within 4 seconds following load rejection, the voltage is $ 4161 V and

4576 V; and

c. Within 4 seconds following load rejection, the frequency is $ 59.7 Hz and # 61.2 Hz. In accordance with the Surveillance Frequency Control Program S

SR 3.8.1.10 SR 3.8.1.10 -------------------NOTE-------------------

1. Credit may be taken for unplanned M03 INSERT 2 events that satisfy this SR.

M02 INSERT 3

2. To ensure Operability of an AVR, it An automatic voltage 3 must have been aligned to the DG regulator (AVR) is only during the performance of either required to be tested once SR 3.8.1.9, SR 3.8.1.10, or A05 each Surveillance interval SR 3.8.1.19 within the last 24 months, during the performance of plus any allowance per SR 3.0.2.

SR 3.8.1.9, SR 3.8.1.10, or SR 3.8.1.19.

Verify each DG, when connected to its bus 24 months LA04 LA02 in parallel with offsite power and SR 3.8.1.10 Note 2 operating with inductive loading that (second sentence) offsite power conditions permit, during and M02 following a load rejection of $ 4450 kW and

4700 kW:

a. Does not trip; and

b. Voltage is maintained # 5450 V.

(continued)

SAN ONOFRE--UNIT 2 3.8-8 Amendment No. 216 Attachment 1, Volume 11, Rev. 0, Page 13 of 437

Attachment 1, Volume 11, Rev. 0, Page 14 of 437 3.8.1 M03 INSERT 2 This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

M02 INSERT 3

2. If performed with the DG synchronized with offsite power, it shall be performed within the power factor limit. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Insert Page 3.8-8 Attachment 1, Volume 11, Rev. 0, Page 14 of 437

Attachment 1, Volume 11, Rev. 0, Page 15 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.11 SR 3.8.1.11 -------------------NOTES-------------------

1. All DG starts may be preceded by an engine prelube period.

2. Credit may be taken for unplanned M03 INSERT 4 events that satisfy this SR.

LA02 Verify on an actual or simulated loss of 24 months offsite power signal:

a. De-energization of emergency buses; In accordance with the Surveillance Frequency

b. Load shedding from emergency buses; Control Program

c. DG auto-starts from standby condition and:

1. energizes permanently connected loads and resets the 4.16kV bus undervoltage relay logic in

10 seconds;

2. maintains steady state voltage

$ 4161 V and # 4576 V;

3. maintains steady state frequency

$ 59.7 Hz and # 61.2 Hz; and

4. supplies permanently connected loads for $ 5 minutes.

(continued)

SAN ONOFRE--UNIT 2 3.8-9 Amendment No. 216 Attachment 1, Volume 11, Rev. 0, Page 15 of 437

Attachment 1, Volume 11, Rev. 0, Page 16 of 437 3.8.1 M03 INSERT 4 This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

Insert Page 3.8-9 Attachment 1, Volume 11, Rev. 0, Page 16 of 437

Attachment 1, Volume 11, Rev. 0, Page 17 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.12 SR 3.8.1.12 -------------------NOTES-------------------

1. All DG starts may be preceded by an engine prelube period.

2. Credit may be taken for unplanned events that satisfy this SR. A06 Engineered Safety Feature (ESF) actuation signal Verify on an actual or simulated SIAS, each 24 months LA07 LA02 DG auto-starts from standby condition and:

a. In # 9.4 seconds, achieves voltage

$ 4161 V and frequency $ 59.7 Hz; In accordance with the Surveillance Frequency

b. Maintains steady state voltage Control Program

$ 4161 V and # 4576 V;

c. Maintains steady state frequency

$ 59.7 Hz and # 61.2 Hz; and

d. Operates for $ 5 minutes.

SR 3.8.1.13 SR 3.8.1.13 -------------------NOTE-------------------

Credit may be taken for unplanned events A06 that satisfy this SR.

noncritical LA02 Verify each DG automatic trip is bypassed 24 months on actual or simulated SIAS except: LA07 ESF actuation signal

a. Engine overspeed; LA05

b. Generator differential current; and

c. Low-low lube oil pressure.

(continued)

SAN ONOFRE--UNIT 2 3.8-10 Amendment No. 216 Attachment 1, Volume 11, Rev. 0, Page 17 of 437

Attachment 1, Volume 11, Rev. 0, Page 18 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.14 SR 3.8.1.14 -------------------NOTES-------------------

1. Momentary transients outside the load range does not invalidate this test.

2. Credit may be taken for unplanned A06 events that satisfy this SR.

INSERT 5

M02 Verify each DG, when connected to its bus 24 months LA02 in parallel with offsite power and LA04 SR 3.8.1.14 Note 3 operating with inductive loading that (second sentence) offsite power conditions permit, operates M02 for $ 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s:

a. For $ 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded $ 4935 kW and

5170 kW; and In accordance with the

b. For the remaining hours of the test Surveillance Frequency Control Program loaded $ 4450 kW and # 4700 kW.

SR 3.8.1.15 SR 3.8.1.15 -------------------NOTES-------------------

1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated $ 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded $ 4450 kW and # 4700 kW.

Momentary transients outside the load range do not invalidate this test.

2. All DG starts may be preceded by an engine prelube period.

Verify each DG starts and: 24 months LA02

a. In # 9.4 seconds, achieves voltage

$ 4161 V and frequency $ 59.7 Hz;

b. Maintains steady state voltage

$ 4161 V and # 4576 V;

c. Maintains steady state frequency

$ 59.7 Hz and # 61.2 Hz; and

d. Operates for $ 5 minutes. L03 (continued)

SAN ONOFRE--UNIT 2 3.8-11 Amendment No. 216 Attachment 1, Volume 11, Rev. 0, Page 18 of 437

Attachment 1, Volume 11, Rev. 0, Page 19 of 437 3.8.1 M02 INSERT 5

2. If performed with DG synchronized with offsite power, it shall be performed within the power factor limit. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Insert Page 3.8-11 Attachment 1, Volume 11, Rev. 0, Page 19 of 437

Attachment 1, Volume 11, Rev. 0, Page 20 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.16 SR 3.8.1.16 -------------------NOTE--------------------

Credit may be taken for unplanned events that satisfy this SR. M03 INSERT 6 Verify each DG: 24 months LA02

a. Is capable of being synchronized with offsite power while loaded with emergency loads upon a simulated restoration of offsite power;

b. Transfers loads to offsite power source; and

c. Returns to ready-to-load operation, with:

In accordance with the

1. steady state voltage $ 4161 V and Surveillance Frequency

4576 V; Control Program LA06

2. steady state frequency $ 59.7 Hz and # 61.2 Hz; and

3. the DG output breaker open.

SR 3.8.1.17 SR 3.8.1.17 -------------------NOTE--------------------

Credit may be taken for unplanned events M03 that satisfy this SR.

INSERT 7 -------------------------------------------

Verify, with a DG operating in test mode 24 months and connected to its bus in parallel with LA02 offsite power, an actual or simulated SIAS LA07 overrides the test mode by:

ESF actuation signal

a. Returning the DG to ready-to-load operation, with:

1. steady state voltage $ 4161 V and

4576 V;

2. steady state frequency $ 59.7 Hz LA06 and # 61.2 Hz; and

3. the DG output breaker open; and

b. Automatically energizing the emergency loads from offsite power.

(continued)

SAN ONOFRE--UNIT 2 3.8-12 Amendment No. 216 Attachment 1, Volume 11, Rev. 0, Page 20 of 437

Attachment 1, Volume 11, Rev. 0, Page 21 of 437 3.8.1 M03 M04 INSERT 6 This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

M03 INSERT 7 This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

Insert Page 3.8-12 Attachment 1, Volume 11, Rev. 0, Page 21 of 437

Attachment 1, Volume 11, Rev. 0, Page 22 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.18 SR 3.8.1.18 -------------------NOTE------------------- In accordance with the A06 Credit may be taken for unplanned events Surveillance Frequency that satisfy this SR. Control Program Verify the timing of each sequenced load 24 months LA02 block is within its timer setting +/- 10% or

+/- 2.5 seconds, whichever is greater, with the exception of the 5 second load group which is -0.5, +2.5 seconds, for each programmed time interval load sequence.

(continued)

SAN ONOFRE--UNIT 2 3.8-13 Amendment No. 127, 169 Attachment 1, Volume 11, Rev. 0, Page 22 of 437

Attachment 1, Volume 11, Rev. 0, Page 23 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.19 SR 3.8.1.19 -------------------NOTES-------------------

1. All DG starts may be preceded by an engine prelube period.

2. Credit may be taken for unplanned M03 INSERT 8 events that satisfy this SR.

3. To ensure Operability of an AVR, it must have been aligned to the DG An automatic voltage regulator during the performance of either (AVR) is only required to be A05 tested once each Surveillance SR 3.8.1.9, SR 3.8.1.10, or interval during the performance SR 3.8.1.19 within the last 24 months, of SR 3.8.1.9, SR 3.8.1.10, or plus any allowance per SR 3.0.2.

SR 3.8.1.19. -------------------------------------------

Verify on an actual or simulated loss of 24 months LA02 offsite power signal in conjunction with actual or simulated ESF actuation signals:

a. De-energization of emergency buses;

b. Load shedding from emergency buses; In accordance with the Surveillance Frequency

c. DG auto-starts from standby condition Control Program and:

1. energizes permanently connected loads and resets the 4.16 kV bus undervoltage relay logic in

10 seconds;

2. energizes auto-connected emergency loads through the programmed time interval load sequence;

3. achieves steady state voltage

$ 4161 V and # 4576 V;

4. achieves steady state frequency

$ 59.7 Hz and # 61.2 Hz; and

5. supplies permanently connected and auto-connected emergency loads for $ 5 minutes.

(continued)

SAN ONOFRE--UNIT 2 3.8-14 Amendment No. 216 Attachment 1, Volume 11, Rev. 0, Page 23 of 437

Attachment 1, Volume 11, Rev. 0, Page 24 of 437 3.8.1 M03 INSERT 8 This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

Insert Page 3.8-14 Attachment 1, Volume 11, Rev. 0, Page 24 of 437

Attachment 1, Volume 11, Rev. 0, Page 25 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.20 SR 3.8.1.20 -------------------NOTE--------------------

All DG starts may be preceded by an engine prelube period.

Verify, when started simultaneously from 10 years LA02 standby condition, each DG:

a. In # 9.4 seconds, achieves voltage In accordance with the

$ 4161 V and frequency $ 59.7 Hz; Surveillance Frequency Control Program

b. Maintains steady state voltage

$ 4161 V and # 4576 V; and

c. Maintains steady state frequency

$ 59.7 Hz and # 61.2 Hz.

SAN ONOFRE--UNIT 2 3.8-15 Amendment No. 216 Attachment 1, Volume 11, Rev. 0, Page 25 of 437

Attachment 1, Volume 11, Rev. 0, Page 26 of 437 ITS AC Sources Operating A01 3.8.1 Table 3.8.1-1 (page 1 of 1)

Diesel Generator Test Schedule NUMBER OF FAILURES IN LAST 25 VALID TESTS(a) FREQUENCY LA02

3 31 days

$ 4 7 days(b)

(but no less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months )

(a) Criteria for determining number of failures and valid tests shall be in accordance with Regulatory Position C.2.1 of Regulatory Guide 1.9, Revision 3, where the number of tests and failures is determined on a per DG basis.

(b) This test frequency shall be maintained until seven consecutive failure free starts from standby conditions and load and run tests have been performed. This is consistent with Regulatory Position C.3.2, of Draft Regulatory Guide DG-1021 (Second Proposed Revision 3 to Regulatory Guide 1.9) (Ref. 14). If, subsequent to the 7 failure free tests, 1 or more additional failures occur, such that there are again 4 or more failures in the last 25 tests, the testing interval shall again be reduced as noted above and maintained until 7 consecutive failure free tests have been performed. This test frequency is also consistent with paragraph (a)(3)(ii) of 10CFR50.63, "Loss of all alternating current power", as published in the Federal Register, Vol. 57, No. 77, page 14517, dated April 21, 1992 (Ref. 15).

SAN ONOFRE--UNIT 2 3.8-16 Amendment No. 127 Attachment 1, Volume 11, Rev. 0, Page 26 of 437

Attachment 1, Volume 11, Rev. 0, Page 27 of 437 ITS AC Sources Operating A01 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources Operating LCO 3.8.1 LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System; and

b. Two diesel generators (DGs) each capable of supplying one train of the onsite Class 1E AC Electrical Power Distribution System.

Applicability APPLICABILITY: MODES 1, 2, 3, and 4. ----------------------NOTE------------------

LCO 3.0.4.b is not applicable to DGs. A02 ACTIONS ---------------------------------------------------

CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One required offsite A.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months circuit inoperable. for required OPERABLE offsite circuit. AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months INSERT 1 thereafter AND M01 A.2 Restore required -----NOTE-------

offsite circuit to The Completion A07 OPERABLE status. Time may be extended to 10 days once per train prior to 7/01/2012 to perform maintenance.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND 17 days from L01 discovery of failure to meet LCO (continued)

SAN ONOFRE--UNIT 3 3.8-1 Amendment No. 217 Attachment 1, Volume 11, Rev. 0, Page 27 of 437

, Volume 11, Rev. 0, Page 28 of 437 3.8.1 M01 INSERT 1 AND A.2 Declare required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from feature(s) with no offsite discovery of no offsite power available power to one train inoperable when its concurrent with redundant required inoperability of feature(s) is inoperable. redundant required feature(s)

Insert Page 3.8-1 , Volume 11, Rev. 0, Page 28 of 437

Attachment 1, Volume 11, Rev. 0, Page 29 of 437 ITS AC Sources Operating A01 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION B B. One required DG inoperable. B.1 Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months A04 for the OPERABLE required offsite AND circuits.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND B.2 Declare required 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from feature(s) supported discovery of by the inoperable DG Condition B inoperable when its concurrent with redundant required inoperability of feature(s) is redundant inoperable. required feature(s)

AND B.3.1 Determine OPERABLE DG 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is not inoperable due to common cause failure.

OR B.3.2 Perform SR 3.8.1.2 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for OPERABLE DG.

AND B.4 Restore required DG 14 days A04 to OPERABLE status.

AND 17 days from discovery of L01 failure to meet LCO (continued)

SAN ONOFRE--UNIT 3 3.8-2 Amendment No. 116133 Attachment 1, Volume 11, Rev. 0, Page 29 of 437

Attachment 1, Volume 11, Rev. 0, Page 30 of 437 ITS AC Sources Operating A01 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION C C. Two required offsite circuits inoperable. C.1 Declare required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from feature(s) inoperable discovery of when its redundant Condition C required feature(s) concurrent with is inoperable. inoperability of redundant required feature(s)

AND C.2 Restore one required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months offsite circuit to OPERABLE status.

ACTION D D. One required offsite ------------NOTE-------------

circuit inoperable. Enter applicable Conditions and Required Actions of AND LCO 3.8.9, "Distribution with no AC power Systems Operating," when source to any train One required DG Condition D is entered. A04 A03 inoperable. -----------------------------

D.1 Restore required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months offsite circuit to OPERABLE status.

OR D.2 Restore required DG 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months A04 to OPERABLE status.

E. Two required DGs E.1 Restore one required 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months A04 inoperable. DG to OPERABLE status.

(continued)

SAN ONOFRE--UNIT 3 3.8-3 Amendment No. 116 Attachment 1, Volume 11, Rev. 0, Page 30 of 437

Attachment 1, Volume 11, Rev. 0, Page 31 of 437 ITS AC Sources Operating A01 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. Required Action and Associated Completion F.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Time of Condition A, B, C, D, or E not met. AND 4 12 F.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months L02 G. Three or more required G.1 Enter LCO 3.0.3. Immediately AC sources inoperable.

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

LCO 3.0.4.a is not applicable when entering MODE 4.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 SR 3.8.1.1 -------------------NOTES-------------------

1. Bus 2A04 is required when unit crosstie breaker 2A0417 is used to LA01 provide a source of AC power.

2. Bus 2A06 is required when unit crosstie breaker 2A0619 is used to In accordance with the Surveillance Frequency provide a source of AC power. Control Program Verify correct breaker alignment and power 7 days LA02 availability for each required offsite circuit.

(continued)

SAN ONOFRE--UNIT 3 3.8-4 Amendment No. 211 Attachment 1, Volume 11, Rev. 0, Page 31 of 437

Attachment 1, Volume 11, Rev. 0, Page 32 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.2 SR 3.8.1.2 -------------------NOTES-------------------

1. Performance of SR 3.8.1.7 satisfies LA03 this SR.

2. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

3. A modified DG start involving idling and gradual acceleration to rated speed may be used for this SR as recommended by the manufacturer. When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.7 must be met.

4. To ensure Operability of an AVR, it must have been aligned to the DG during the performance of SR 3.8.1.2 A05 An automatic voltage regulator (AVR) is only required to be tested once per and SR 3.8.1.3 within the last In accordance with the two Surveillance intervals. 60 days, plus any allowance per Surveillance Frequency Control Program SR 3.0.2.

Verify each DG starts from standby As specified in conditions and achieves: Table 3.8.1-1 LA02

a. Steady state voltage $ 4161 V and

4576 V; and

b. Steady state frequency $ 59.7 Hz and

61.2 Hz.

(continued)

SAN ONOFRE--UNIT 3 3.8-5 Amendment No. 208

Attachment 1, Volume 11, Rev. 0, Page 32 of 437

Attachment 1, Volume 11, Rev. 0, Page 33 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.3 SR 3.8.1.3 -------------------NOTES-------------------

1. DG loadings may include gradual loading as recommended by the manufacturer.

2. Momentary transients outside the load range do not invalidate this test.

3. This Surveillance shall be conducted on only one DG at a time.

4. This SR shall be preceded by, and immediately follow without shutdown, a successful performance of SR 3.8.1.2 or SR 3.8.1.7.

5. To ensure Operability of an AVR, it must have been aligned to the DG An AVR is only required to be tested during the performance of SR 3.8.1.2 once per two Surveillance intervals.

A05 and SR 3.8.1.3 within the last 60 days, plus any allowance per SR 3.0.2.

Verify each DG is synchronized and loaded, As specified in and operates for $ 60 minutes at a load Table 3.8.1-1 LA02

$ 4450 kW and # 4700 kW.

SR 3.8.1.4 SR 3.8.1.4 Verify each day tank contains $ 31.5 inches 31 days LA08 LA02 of fuel oil. a fuel oil level > 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of DG operation at full load plus 10% In accordance with the Surveillance Frequency Control Program SR 3.8.1.5 SR 3.8.1.5 Check for and remove accumulated water from 31 days LA02 each day tank.

SR 3.8.1.6 SR 3.8.1.6 Verify the fuel oil transfer system 31 days LA02 operates to transfer fuel oil from storage tank to the day tank.

(continued)

SAN ONOFRE--UNIT 3 3.8-6 Amendment No. 203

Attachment 1, Volume 11, Rev. 0, Page 33 of 437

Attachment 1, Volume 11, Rev. 0, Page 34 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.7 SR 3.8.1.7 ------------------NOTES--------------------

1. All DG starts may be preceded by an engine prelube period.

2. Credit may be taken for unplanned 184 days A06 LA02 events that satisfy this SR.

Verify each DG starts from standby condition and:

a. In # 9.4 seconds, achieves voltage

$ 4161 V and frequency $ 59.7 Hz; In accordance with the Surveillance Frequency Control Program

b. Maintains steady state voltage

$ 4161 V and # 4576 V; and

c. Maintains steady state frequency

$ 59.7 Hz and # 61.2 Hz.

SR 3.8.1.8 -------------------NOTE------------------

1. Credit may be taken for unplanned M03 This Surveillance shall not events that satisfy this SR.

normally be performed in MODE 1 or 2. However, this Surveillance may be 2. Testing to satisfy this SR shall 24 months LA02 performed to reestablish include actual automatic and manual OPERABILITY provided an transfer to at least one alternate assessment determines the safety of the plant is offsite circuit. The other alternate maintained or enhanced. offsite circuit may be verified by overlapping circuit tests.

Verify capability of automatic and manual transfer of AC power sources from the normal offsite circuit to each alternate required offsite circuit.

(continued)

SAN ONOFRE--UNIT 3 3.8-7 Amendment No. 208 Attachment 1, Volume 11, Rev. 0, Page 34 of 437

Attachment 1, Volume 11, Rev. 0, Page 35 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY S

SR 3.8.1.9 SR 3.8.1.9 -------------------NOTE-------------------

1. Credit may be taken for unplanned M03 INSERT 2 events that satisfy this SR.

INSERT 3 M02

2. To ensure Operability of an AVR, it An automatic voltage 3 must have been aligned to the DG regulator (AVR) is only during the performance of either required to be tested once A05 each Surveillance interval SR 3.8.1.9, SR 3.8.1.10, or during the performance of SR 3.8.1.19 within the last 24 months, SR 3.8.1.9, SR 3.8.1.10, or plus any allowance per SR 3.0.2.

SR 3.8.1.19. ------------------------------------------

Verify each DG rejects a load greater than 24 months LA02 or equal to its associated single largest post-accident load, and:

a. Following load rejection, the frequency is # 66.75 Hz;

b. Within 4 seconds following load rejection, the voltage is $ 4161 V and

4576 V; and

c. Within 4 seconds following load rejection, the frequency is $ 59.7 Hz In accordance with the and # 61.2 Hz. Surveillance Frequency S Control Program SR 3.8.1.10 SR 3.8.1.10 -------------------NOTE-------------------

1. Credit may be taken for unplanned INSERT 2 events that satisfy this SR. M03 M02 INSERT 3

2. To ensure Operability of an AVR, it An automatic voltage 3 must have been aligned to the DG regulator (AVR) is only required to be tested once during the performance of either each Surveillance interval SR 3.8.1.9, SR 3.8.1.10, or during the performance of SR 3.8.1.19 within the last 24 months, A05 SR 3.8.1.9, SR 3.8.1.10, or plus any allowance per SR 3.0.2.

SR 3.8.1.19. ------------------------------------------

Verify each DG, when connected to its bus 24 months LA04 LA02 in parallel with offsite power and SR 3.8.1.10 Note 2 operating with inductive loading that (second sentence) offsite power conditions permit, during and M02 following a load rejection of $ 4450 kW and

4700 kW:

a. Does not trip; and

b. Voltage is maintained # 5450 V.

(continued)

SAN ONOFRE--UNIT 3 3.8-8 Amendment No. 208 Attachment 1, Volume 11, Rev. 0, Page 35 of 437

Attachment 1, Volume 11, Rev. 0, Page 36 of 437 3.8.1 M03 INSERT 2 This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

M02 INSERT 3

2. If performed with the DG synchronized with offsite power, it shall be performed within the power factor limit. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Insert Page 3.8-8 Attachment 1, Volume 11, Rev. 0, Page 36 of 437

Attachment 1, Volume 11, Rev. 0, Page 37 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.11 SR 3.8.1.11 -------------------NOTES-------------------

1. All DG starts may be preceded by an engine prelube period.

2. Credit may be taken for unplanned M03 INSERT 4 events that satisfy this SR.

24 months LA02 Verify on an actual or simulated loss of offsite power signal:

a. De-energization of emergency buses; In accordance with the Surveillance Frequency Control Program

b. Load shedding from emergency buses;

c. DG auto-starts from standby condition and:

1. energizes permanently connected loads and resets the 4.16kV bus undervoltage relay logic in

10 seconds;

2. maintains steady state voltage

$ 4161 V and # 4576 V;

3. maintains steady state frequency

$ 59.7 Hz and # 61.2 Hz; and

4. supplies permanently connected loads for $ 5 minutes.

(continued)

SAN ONOFRE--UNIT 3 3.8-9 Amendment No. 208 Attachment 1, Volume 11, Rev. 0, Page 37 of 437

Attachment 1, Volume 11, Rev. 0, Page 38 of 437 3.8.1 M03 INSERT 4 This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

Insert Page 3.8-9 Attachment 1, Volume 11, Rev. 0, Page 38 of 437

Attachment 1, Volume 11, Rev. 0, Page 39 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.12 SR 3.8.1.12 -------------------NOTES-------------------

1. All DG starts may be preceded by an engine prelube period.

2. Credit may be taken for unplanned events that satisfy this SR. A06 Engineered Safety Feature (ESF) actuation signal Verify on an actual or simulated SIAS, each 24 months LA07 LA02 DG auto-starts from standby condition and:

a. In # 9.4 seconds, achieves voltage In accordance with the

$ 4161 V and frequency $ 59.7 Hz; Surveillance Frequency Control Program

b. Maintains steady state voltage

$ 4161 V and # 4576 V; and

c. Maintains steady state frequency

$ 59.7 Hz and # 61.2 Hz.

d. Operates for $ 5 minutes.

SR 3.8.1.13 SR 3.8.1.13 -------------------NOTE-------------------

Credit may be taken for unplanned events In accordance with the that satisfy this SR. Surveillance Frequency A06 Control Program noncritical Verify each DG automatic trip is bypassed on actual or simulated SIAS except: 24 months LA07 LA02

a. Engine overspeed; ESF actuation signal

b. Generator differential current; and LA05

c. Low-low lube oil pressure.

(continued)

SAN ONOFRE--UNIT 3 3.8-10 Amendment No. 208 Attachment 1, Volume 11, Rev. 0, Page 39 of 437

Attachment 1, Volume 11, Rev. 0, Page 40 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.14 SR 3.8.1.14 -------------------NOTES-------------------

1. Momentary transients outside the load range does not invalidate this test.

2. Credit may be taken for unplanned A06 events that satisfy this SR.

INSERT 5 M02 Verify each DG, when connected to its bus 24 months LA02 in parallel with offsite power and LA04 SR 3.8.1.14 Note 3 operating with inductive loading that offsite power conditions permit, operates M02 (second sentence) for $ 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s:

a. For $ 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded $ 4935 kW and

5170 kW; and In accordance with the Surveillance Frequency Control Program

b. For the remaining hours of the test loaded $ 4450 kW and # 4700 kW.

SR 3.8.1.15 SR 3.8.1.15 -------------------NOTES-------------------

1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated $ 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded $ 4450 kW and # 4700 kW.

Momentary transients outside the load range do not invalidate this test.

In accordance with the Surveillance Frequency

2. All DG starts may be preceded by an Control Program engine prelube period.

Verify each DG starts and: 24 months LA02

a. In # 9.4 seconds, achieves voltage

$ 4161 V and frequency $ 59.7 Hz;

b. Maintains steady state voltage

$ 4161 V and # 4576 V;

c. Maintains steady state frequency

$ 59.7 Hz and # 61.2 Hz; and

d. Operates for $ 5 minutes. L03 (continued)

SAN ONOFRE--UNIT 3 3.8-11 Amendment No. 208 Attachment 1, Volume 11, Rev. 0, Page 40 of 437

Attachment 1, Volume 11, Rev. 0, Page 41 of 437 3.8.1 M02 INSERT 5

2. If performed with DG synchronized with offsite power, it shall be performed within the power factor limit. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

Insert Page 3.8-11 Attachment 1, Volume 11, Rev. 0, Page 41 of 437

Attachment 1, Volume 11, Rev. 0, Page 42 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.16 SR 3.8.1.16 -------------------NOTE--------------------

Credit may be taken for unplanned events M03 that satisfy this SR.

INSERT 6 -------------------------------------------

Verify each DG: 24 months LA02

a. Is capable of being synchronized with offsite power while loaded with emergency loads upon a simulated restoration of offsite power;

b. Transfers loads to offsite power source; and

c. Returns to ready-to-load operation, with: In accordance with the Surveillance Frequency

1. steady state voltage $ 4161 V and Control Program

4576 V;

2. steady state frequency $ 59.7 Hz and # 61.2 Hz; and LA06

3. the DG output breaker open.

SR 3.8.1.17 SR 3.8.1.17 -------------------NOTE--------------------

Credit may be taken for unplanned events M03 that satisfy this SR.

INSERT 7 -------------------------------------------

Verify, with a DG operating in test mode 24 months LA02 and connected to its bus in parallel with offsite power, an actual or simulated SIAS LA07 overrides the test mode by: ESF actuation signal

a. Returning the DG to ready-to-load operation, with:

1. steady state voltage $ 4161 V and

4576 V;

2. steady state frequency $ 59.7 Hz LA06 and # 61.2 Hz; and

3. the DG output breaker open; and

b. Automatically energizing the emergency loads from offsite power.

(continued)

SAN ONOFRE--UNIT 3 3.8-12 Amendment No. 208 Attachment 1, Volume 11, Rev. 0, Page 42 of 437

Attachment 1, Volume 11, Rev. 0, Page 43 of 437 3.8.1 M03 M04 INSERT 6 This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

M03 INSERT 7 This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

Insert Page 3.8-12 Attachment 1, Volume 11, Rev. 0, Page 43 of 437

Attachment 1, Volume 11, Rev. 0, Page 44 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.18 SR 3.8.1.18 -------------------NOTE------------------- In accordance with the A06 Credit may be taken for unplanned events Surveillance Frequency that satisfy this SR. Control Program 24 months Verify the timing of each sequenced load LA02 block is within its timer setting +/- 10% or

+/- 2.5 seconds, whichever is greater, with the exception of the 5 second load group which is -0.5, +2.5 seconds, for each programmed time interval load sequence.

(continued)

SAN ONOFRE--UNIT 3 3.8-13 Amendment No. 116, 160 Attachment 1, Volume 11, Rev. 0, Page 44 of 437

Attachment 1, Volume 11, Rev. 0, Page 45 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.19 SR 3.8.1.19 -------------------NOTES-------------------

1. All DG starts may be preceded by an engine prelube period.

2. Credit may be taken for unplanned INSERT 8 M03 events that satisfy this SR.

3. To ensure Operability of an AVR, it must have been aligned to the DG An automatic voltage regulator (AVR) is only required to be during the performance of either A05 tested once each Surveillance SR 3.8.1.9, SR 3.8.1.10, or interval during the performance SR 3.8.1.19 within the last 24 months, of SR 3.8.1.9, SR 3.8.1.10, or plus any allowance per SR 3.0.2.

SR 3.8.1.19.

Verify on an actual or simulated loss of 24 months LA02 offsite power signal in conjunction with actual or simulated ESF actuation signals:

In accordance with the

a. De-energization of emergency buses; Surveillance Frequency Control Program

b. Load shedding from emergency buses;

c. DG auto-starts from standby condition and:

1. energizes permanently connected loads and resets the 4.16 kV bus undervoltage relay logic in

10 seconds;

2. energizes auto-connected emergency loads through the programmed time interval load sequence;

3. achieves steady state voltage

$ 4161 V and # 4576 V;

4. achieves steady state frequency

$ 59.7 Hz and # 61.2 Hz; and

5. supplies permanently connected and auto-connected emergency loads for $ 5 minutes.

(continued)

SAN ONOFRE--UNIT 3 3.8-14 Amendment No. 208 Attachment 1, Volume 11, Rev. 0, Page 45 of 437

Attachment 1, Volume 11, Rev. 0, Page 46 of 437 3.8.1 M03 INSERT 8 This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

Insert Page 3.8-14 Attachment 1, Volume 11, Rev. 0, Page 46 of 437

Attachment 1, Volume 11, Rev. 0, Page 47 of 437 ITS AC Sources Operating A01 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.20 SR 3.8.1.20 -------------------NOTE--------------------

All DG starts may be preceded by an engine prelube period.

Verify, when started simultaneously from 10 years LA02 standby condition, each DG:

a. In # 9.4 seconds, achieves voltage In accordance with the

$ 4161 V and frequency $ 59.7 Hz; Surveillance Frequency Control Program

b. Maintains steady state voltage

$ 4161 V and # 4576 V; and

c. Maintains steady state frequency

$ 59.7 Hz and # 61.2 Hz.

SAN ONOFRE--UNIT 3 3.8-15 Amendment No. 208

Attachment 1, Volume 11, Rev. 0, Page 47 of 437

Attachment 1, Volume 11, Rev. 0, Page 48 of 437 ITS AC Sources Operating A01 3.8.1 Table 3.8.1-1 (page 1 of 1)

Diesel Generator Test Schedule NUMBER OF FAILURES IN LAST 25 VALID TESTS(a) FREQUENCY

3 31 days LA02

$ 4 7 days (b)

(but no less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months )

(a) Criteria for determining number of failures and valid tests shall be in accordance with Regulatory Position C.2.1 of Regulatory Guide 1.9, Revision 3, where the number of tests and failures is determined on a per DG basis.

(b) This test frequency shall be maintained until seven consecutive failure free starts from standby conditions and load and run tests have been performed. This is consistent with Regulatory Position C.3.2, of Draft Regulatory Guide DG-1021 (Second Proposed Revision 3 to Regulatory Guide 1.9) (Ref. 14). If, subsequent to the 7 failure free tests, 1 or more additional failures occur, such that there are again 4 or more failures in the last 25 tests, the testing interval shall again be reduced as noted above and maintained until 7 consecutive failure free tests have been performed. This test frequency is also consistent with paragraph (a)(3)(ii) of 10CFR50.63, "Loss of all alternating current power", as published in the Federal Register, Vol. 57, No. 77, page 14517, dated April 21, 1992 (Ref. 15).

SAN ONOFRE--UNIT 3 3.8-16 Amendment No. 116 Attachment 1, Volume 11, Rev. 0, Page 48 of 437

Attachment 1, Volume 11, Rev. 0, Page 49 of 437 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES-OPERATING 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 3.8.1 ACTIONS include a Note that states LCO 3.0.4.b is not applicable.

CTS 3.8.1 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 3.8.1 ACTIONS Note is to prohibit entry into the Applicability of LCO 3.8.1 with an inoperable AC electrical source (offsite circuit or DG). Currently, CTS 3.8.1 and LCO 3.0.4 preclude entering MODE 4 when an AC electrical source 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 restriction (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 AC electrical source, and therefore the provisions of LCO 3.0.4.b should not be applied in this circumstance. The change is acceptable because CTS 3.8.1 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 3.8.1 Required Actions D.1 and D.2 are modified by a Note which requires entry into applicable Conditions and Required Actions of LCO 3.8.9, Distribution Systems - Operating, when Condition D is entered. ITS Required Actions D.1 and D.2 are modified by a Note which requires entry into applicable Conditions and Required Actions of LCO 3.8.9, Distribution Systems - Operating, when Condition D is entered with no AC power source to any train. This changes the CTS by adding clarifying words to the Required Action Note.

The purpose of the CTS 3.8.1 Required Actions D.1 and D.2 Note is to ensure the ACTIONS of LCO 3.8.9, Distribution Systems - Operating Specification is entered when one offsite circuit and one DG are inoperable. The assumption is, as described in the CTS Bases, that these inoperabilities result in no AC power to a train. Otherwise, pursuant to LCO 3.0.6, LCO 3.8.9 would not be entered, even if all AC sources to it were inoperable resulting in de-energization. The San Onofre Unit 2 and 3 Page 1 of 15 Attachment 1, Volume 11, Rev. 0, Page 49 of 437

Attachment 1, Volume 11, Rev. 0, Page 50 of 437 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES-OPERATING proposed change is acceptable because it clarifies that LCO 3.8.9 should be entered when there is no AC power source to any train (offsite circuit or DG) without regard to whether the train is de-energized. This change is designated as administrative because clarifying words are being added to the Required Action Note without technically changing the intent.

A04 CTS 3.8.1 ACTION B and ACTION D (second Condition) provide actions when a "required" DG is inoperable and Required Actions B.4 and D.2 require the restoration of the "required" DG to OPERABLE status. CTS 3.8.1 ACTION E provides actions when two required DGs are inoperable and Required Action E.1 requires restoration of one required DG to OPERABLE status. ITS 3.8.1 ACTION B, ACTION D, and ACTION E require similar actions as the CTS, but do not use "required" when referring to the DGs. This changes the CTS by deleting the word "required" when used in conjunction with DGs from CTS 3.8.1 ACTION B, ACTION D, and ACTION E.

The purpose of the CTS LCO 3.8.1 is to ensure the AC electrical sources are available to provide the required power to shut down the reactor and maintain it in a safety shutdown condition after an AOO or postulated DBA. The proposed change deletes the word "required" from CTS 3.8.1 ACTIONS when used in conjunction with DG. This change is acceptable because the word "required" is not needed in "required DG" because the LCO stipulates that two DGs shall be OPERABLE. SONGS has only two DGs and both are required to be OPERABLE. The term required is used when there are more installed systems, structures, or components (SSCs) than are required to be OPERABLE. This change is designated as administrative because no technical changes are being made to the Specification.

A05 CTS SRs 3.8.1.2 and 3.8.1.3 are modified by a Note (Note 4 for SR 3.8.1.2 and Note 5 for SR 3.8.1.3) which states that to ensure Operability of an automatic voltage regulator (AVR), it must have been aligned to the DG during the performance of SR 3.8.1.2 and SR 3.8.1.3 within the last 60 days, plus any allowance per SR 3.0.2. CTS SRs 3.8.1.9, 3.8.1.10, and 3.8.1.19 are modified by a Note (Note 2 for SRs 3.8.1.9 and 3.8.1.10 and Note 3 for SR 3.8.1.19) which states that to ensure Operability of an AVR, it must have been aligned to the DG during the performance of SR 3.8.1.9, SR 3.8.1.10, or SR 3.8.1.19 within the last 24 months, plus any allowance per SR 3.0.2. ITS SRs 3.8.1.2 and 3.8.1.3 are modified by a Note (Note 3 for SR 3.8.1.2 and Note 5 for SR 3.8.1.3) which states that an automatic voltage regulator (AVR) is only required to be tested once per two Surveillance intervals. ITS SRs 3.8.1.9, 3.8.1.10, and 3.8.1.19 are modified by a Note (Note 3) which states that an automatic voltage regulator (AVR) is only required to be tested once each surveillance interval during the performance of either SR 3.8.1.9, SR 3.8.1.10, or SR 3.8.1.19. This changes the CTS by rewording AVR Notes in SRs 3.8.1.2, 3.8.1.3, 3.8.1.9, 3.8.1.10, and 3.8.1.19.

The purpose of the AVR Note in CTS SRs 3.8.1.2, 3.8.1.3, 3.8.1.9, 3.8.1.10, and 3.8.1.19 is to ensure each AVR is tested once within the past 60 days with SRs 3.8.1.2 and 3.8.1.3 and tested once, with either SR 3.8.1.9, SR 3.8.1.10, or SR 3.8.1.19 in the past 24 months. The SONGS design includes two AVRs, either of which can perform the required function. Thus the Notes allow both AVRs to be San Onofre Unit 2 and 3 Page 2 of 15 Attachment 1, Volume 11, Rev. 0, Page 50 of 437

Attachment 1, Volume 11, Rev. 0, Page 51 of 437 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES-OPERATING OPERABLE, provided, for SRs 3.8.1.2 and 3.8.1.3, the AVRs have been tested every 60 days (essentially, one out of every 2 Surveillance intervals), and for SRs 3.8.1.9, 3.8.1.10, and 3.8.1.19, each AVR is tested during performance of at least one of the three SRs each Surveillance interval (i.e., one AVR is tested during one of the three SRs and the other AVR is tested during the other two SRs). The proposed change is editorial in that it rewords the Notes to be more consistent with the ISTS format without changing the intent of the Note. This change is designated as administrative because no technical changes are being made to the Specification.

A06 CTS SR 3.8.1.7, SR 3.8.1.12, SR 3.8.1.13, SR 3.8.1.14, and SR 3.8.1.18 include a Note that states credit may be taken for unplanned events that satisfy this SR.

ITS SR 3.8.1.7, SR 3.8.1.12, SR 3.8.1.13, SR 3.8.1.14, and SR 3.8.1.18 do not include this Note. This changes the CTS by deleting this Note.

The purpose of the Note is to allow an unplanned event to be credited with meeting the applicable SR, provided the necessary data is obtained. However, this Note is unnecessary and redundant, since nothing in the CTS nor ITS currently precludes an unplanned event from being used to meet an SR. As long as the necessary data is obtained to prove an SR is satisfactorily met, any event, whether planned or unplanned, can be credited with meeting an SR. Therefore, this redundant Note has been deleted. This change is acceptable and designated as administrative since the technical requirements have not been changed.

A07 CTS 3.8.1 Required Action A.2 includes a Note to the Completion Time that states that the Completion Time may be extended to 10 days (from the normal 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time) once per train prior to 7/01/2012 to perform maintenance. ITS 3.8.1 Required Action A.3 (the ITS equivalent of CTS 3.8.1 Required Action A.2) does not include this allowance. This changes the CTS by deleting this one-time exception to the normal 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time to restore an inoperable DG.

The purpose of the Note was to provide SONGS Units 2 and 3 with a one-time exception to the normal 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time for restoring an inoperable DG.

This allowance was approved as part of License Amendments 224 and 217. The Note only provides the exception until 7/01/2012. Thus, by the time the ITS is scheduled to be implemented at SONGS Units 2 and 3, the allowed date (7/01/2012) for using the exception will have expired. Therefore, deletion of this one-time allowance is acceptable and designated as administrative.

MORE RESTRICTIVE CHANGES M01 CTS 3.8.1 ACTION A provides actions when one required offsite circuit is inoperable. ITS 3.8.1 ACTION A provides similar actions when one required offsite circuit is inoperable, but also contains an additional Required Action (Required Action A.2) that requires declaring required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable.

ITS 3.8.1 Required Action A.2 is required to be completed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s). This changes the CTS by adding a Required San Onofre Unit 2 and 3 Page 3 of 15 Attachment 1, Volume 11, Rev. 0, Page 51 of 437

Attachment 1, Volume 11, Rev. 0, Page 52 of 437 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES-OPERATING Action to declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable.

The purpose of ITS 3.8.1 Required Action A.2 is to provide assurance that an event coincident with a single failure of the associated DG will not result in a complete loss of safety function of critical redundant required features. The proposed change adds an additional Required Action when one required offsite circuit is inoperable to declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s). The CTS would allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months if no offsite power is available to a feature based on the CTS definition of OPERABILITY which requires normal or emergency power. Inoperability of these required feature(s) concurrent with a loss of the associated DG can result in a loss of function. This change is designated as more restrictive because additional requirements are added to the ACTIONS of the ITS that are not currently in the CTS.

M02 CTS SR 3.8.1.9, SR 3.8.1.10, and SR 3.8.1.14 provide requirements for DG testing. For CTS SR 3.8.1.10 and SR 3.8.1.14, the Surveillances include a requirement that the test should be performed, when operating paralleled with offsite power, at the inductive loading that offsite power conditions permit. ITS SR 3.8.1.9, SR 3.8.1.10, and SR 3.8.1.14 provide similar requirements, but contain a Note (Note 2) which states, If performed with the DG synchronized with offsite power, it shall be performed within the power factor limit. However, if grid conditions do not permit, the power factor limit is not required to be met.

Under this condition the power factor shall be maintained as close to the limit as practicable. This changes the CTS by adding the power factor Note to these Surveillances.

The purpose of the ITS Note is to ensure that the DG is tested under load conditions that are as close to design basis conditions as possible. The proposed change adds a power factor Note to some CTS Surveillances. This Note will ensure the DG is tested at a power factor that is representative of the actual inductive loading a DG would see under design basis accident conditions, while ensuring it is compatible with the grid conditions. This change is designated as more restrictive because an additional requirement is added to ITS Surveillances that is not currently in the CTS.

M03 CTS SR 3.8.1.8, CTS SR 3.8.1.9, and CTS SR 3.8.1.10 contain a Note (Note 1) which states, "Credit may be taken for unplanned events that satisfy this SR."

ITS SR 3.8.1.8, ITS SR 3.8.1.9, and ITS SR 3.8.1.10 Note 1 modifies this Note by stating that the Surveillance shall not normally be performed in MODE 1 or 2.

CTS SR 3.8.1.11 and CTS 3.8.1.19 contain a Note (Note 2) which states, "Credit may be taken for unplanned events that satisfy this SR." ITS SR 3.8.1.11 and ITS SR 3.8.1.19 Note 2 modifies this Note by stating that the Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. CTS SR 3.8.1.16 and CTS SR 3.8.1.17 contain a Note which states, "Credit may be taken for unplanned events that satisfy this SR." ITS SR 3.8.1.16 and ITS SR 3.8.1.17 Notes modify this Note by stating that the Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. Additionally, all of these ITS SR Notes state that either the Surveillance or portions of the Surveillance may be performed to reestablish San Onofre Unit 2 and 3 Page 4 of 15 Attachment 1, Volume 11, Rev. 0, Page 52 of 437

Attachment 1, Volume 11, Rev. 0, Page 53 of 437 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES-OPERATING OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. This changes the CTS by allowing the Surveillances (or portions of the Surveillances, as applicable) to be performed in their respective MODES only as long as an assessment is performed.

The purpose of the CTS SR 3.8.1.8 is to confirm the OPERABILITY of the alternate circuit distribution network to power shutdown loads. The purpose of the remaining CTS SRs is to confirm the OPERABILITY of the DGs. This change is acceptable because all of these SRs are normally performed during plant shutdown conditions. This change is designated as more restrictive because explicit restrictions are being added.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS SR 3.8.1.1 requires verifying the correct breaker alignment and power availability for each required offsite circuit. The SR is modified by two notes which state Bus 3A04 (unit 2) and 2A04 (unit 3) is required when unit crosstie breaker 3A0416 (unit 2) and 2A0417 (unit 3) is used to provide a source of AC power (Note 1) and Bus 3A06 (unit 2) and 2A06 (unit 3) is required when unit crosstie breaker 3A0603 (unit 2) and 2A0619 (unit 3) is used to provide a source of AC power (Note 2). ITS SR 3.8.1.1 requires a similar Surveillance, but does not contain the Notes. This changes the CTS by moving the requirements in the CTS Notes to the Bases.

The removal of the requirement for Buses 3A04, 3A06, 2A04, and 2A06 to be required when crosstie breakers 3A0416, 3A603, 2A0417, and 2A0619, respectively, are used to provide a source of AC power 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. CTS and ITS SR 3.8.1.1 still require verification of correct breaker alignment and power availability for each required offsite circuit. The procedural information in the Note is not required for inclusion in the Specification and is being moved to the Bases. 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 are being moved from the Technical Specifications to the ITS Bases.

LA02 (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 3.8.1.1 through SR 3.8.1.20 requires verifying that the AC electrical sources can and will operate as designed at the San Onofre Unit 2 and 3 Page 5 of 15 Attachment 1, Volume 11, Rev. 0, Page 53 of 437

Attachment 1, Volume 11, Rev. 0, Page 54 of 437 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES-OPERATING specified Surveillance Frequencies listed for each SR and in CTS Table 3.8.1-1.

ITS SR 3.8.1.1 through SR 3.8.1.20 requires similar Surveillances; however, the specific periodic Frequencies are being replaced with "In accordance with the Surveillance Frequency Control Program." This also includes relocating the Frequency requirements in CTS Table 3.8.1-1 to 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, provides a detailed description of the process to be followed when considering changes to a Surveillance Frequency.

NEI 04-10 will be reviewed and approved by the NRC separately from this Traveler. Therefore, the process is not discussed further here.

San Onofre Unit 2 and 3 Page 6 of 15 Attachment 1, Volume 11, Rev. 0, Page 54 of 437

Attachment 1, Volume 11, Rev. 0, Page 55 of 437 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES-OPERATING 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.

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; San Onofre Unit 2 and 3 Page 7 of 15 Attachment 1, Volume 11, Rev. 0, Page 55 of 437

Attachment 1, Volume 11, Rev. 0, Page 56 of 437 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES-OPERATING 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 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.

San Onofre Unit 2 and 3 Page 8 of 15 Attachment 1, Volume 11, Rev. 0, Page 56 of 437

Attachment 1, Volume 11, Rev. 0, Page 57 of 437 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES-OPERATING

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

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

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

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

LA03 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS SR 3.8.1.2 requires verifying each DG starts from standby conditions. The SR is modified by a Note (Note 1) which states performance of SR 3.8.1.7 satisfies this SR. ITS SR 3.8.1.2 requires the same Surveillance but does not contain a Note similar to CTS Note 1. This changes the CTS by moving the requirements in the CTS Note to the Bases.

The removal of the requirement that performance of SR 3.8.1.7 satisfies SR 3.8.1.2 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. CTS and ITS SR 3.8.1.2 still require verification each DG starts from standby conditions. The procedural information in the Note is not required for inclusion in the Specification and is being moved to the Bases. 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 are being moved from the Technical Specifications to the ITS Bases.

LA04 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS SR 3.8.1.10 requires verifying that each DG, when connected to its bus in parallel with offsite power, during and following a load rejection 4450 kW and 4700 kW does not trip and voltage is maintained 5450 V. CTS SR 3.8.1.14 requires verifying that each DG, when connected to its bus in parallel with offsite power, operates for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months loaded 4935 kW and 5170 kW and for the remaining hours of the test loaded 4450 kW and 4700 kW. ITS SR 3.8.1.10 and SR 3.8.1.14 require the same requirements except the descriptive information, when connected to its bus in parallel with offsite power, included in the CTS will not be included in the ITS.

This changes the CTS by moving the descriptive information, when connected to its bus in parallel with offsite power, to the Bases.

The removal of the CTS SR 3.8.1.10 and SR 3.8.1.14 information stating the DG requirements during the load rejection test 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 SR 3.8.1.10 still San Onofre Unit 2 and 3 Page 9 of 15 Attachment 1, Volume 11, Rev. 0, Page 57 of 437

Attachment 1, Volume 11, Rev. 0, Page 58 of 437 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES-OPERATING requires verifying the capability of each DG during a load rejection and ITS SR 3.8.1.14 still requires a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months DG run. The procedural information in the SR is not required for inclusion in the Specification to adequately perform the SR.

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 are being moved from the Technical Specifications to the ITS Bases.

LA05 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS SR 3.8.1.13 requires verifying that each DG automatic trip is bypassed on an actual or simulated SIAS except: engine overspeed, generator differential current, and low-low lube oil pressure. ITS SR 3.8.1.13 requires verifying each DG noncritical automatic trip is bypassed on an actual or simulated ESF actuation signal. This changes the CTS by adding the term noncritical in the SR and moving the list of trips that will not be bypassed to the Bases.

The removal of the CTS SR 3.8.1.13 listing of the DG automatic trips that will not be bypassed and adding the descriptive term noncritical to the SR 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 SR 3.8.1.13 still requires verifying each DG non-critical automatic trips are bypassed on an ESF actuation signal. The three trips currently listed in the CTS SR are critical trips. The performance of the CTS and ITS SRs are not being affected; only descriptive information is being moved to the Bases. The procedural information in the SR is not required for inclusion in the Specification to adequately perform the SR. 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 are being moved from the Technical Specifications to the ITS Bases.

LA06 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS SR 3.8.1.16 and SR 3.8.1.17, as part of their respective tests, require the DG to return to ready-to-load operation with steady state voltage 4161 V and 4576 V; steady state frequency 59.7 Hz and 61.2 Hz; and the DG output breaker open. ITS SR 3.8.1.16 and SR 3.8.1.17 require the same Surveillances; however, the ITS does not list the specific criteria for returning the DG to ready-to-load operation. This changes the CTS by moving the specific ready-to-load criteria to the Bases.

The removal of the CTS SR 3.8.1.16 and SR 3.8.1.17 specific criteria for returning the DG to ready-to-load operation 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 SR 3.8.1.16 and SR 3.8.1.17 still require performance of their respective SRs. The performance of the ITS SRs are not being affected; only descriptive information is being San Onofre Unit 2 and 3 Page 10 of 15 Attachment 1, Volume 11, Rev. 0, Page 58 of 437

Attachment 1, Volume 11, Rev. 0, Page 59 of 437 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES-OPERATING moved to the Bases. The procedural information in the SR is not required for inclusion in the Specification to adequately perform the SR. 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 are being moved from the Technical Specifications to the ITS Bases.

LA07 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS SR 3.8.1.12 requires verification of DG auto-start from standby condition on an actual or simulated safety injection actuation signal (SIAS). CTS SR 3.8.1.13 requires verification that the DG automatic trip is bypassed on an actual or simulated SIAS. CTS SR 3.8.1.17 requires verification that the test mode is overridden on an actual or simulated SIAS. ITS contains similar Surveillance Requirements but on an actual or simulated ESF Actuation Signal. This changes the CTS by moving the safety injection actuation signal to the Bases.

This change is acceptable because the ESF Actuation Signal for the diesel generators is the safety injection actuation signal. The removal of the CTS SR 3.8.1.12, SR 3.8.1.13, and SR 3.8.1.17 specific criteria for actual or simulated signal 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 SR 3.8.1.12, SR 3.8.1.13, and SR 3.8.1.17 still require performance of their respective SRs. The performance of the ITS SRs are not being affected; only descriptive information is being moved to the Bases. The procedural information in the SR is not required for inclusion in the Specification to adequately perform the SR. 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 are being moved from the Technical Specifications to the ITS Bases.

LA08 (Type 4 - Removing Details of System Design and System Description, Including Design Limits) CTS SR 3.8.1.4 requires verifying that each day tank contains a fuel oil level 31.5 inches of fuel oil. ITS SR 3.8.1.4 requires verifying that each day tank contains a fuel oil level 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of DG operation at full load plus 10%.

This changes the CTS by moving the specific value for the fuel volume to the Bases.

The removal of these details from the Technical Specification is acceptable because this type of information is not necessary to provide adequate protection of public health and safety. The purpose of CTS SR 3.8.1.4 is to ensure that the diesel generator has sufficient fuel oil to operate the DG at full power plus 10 %

for greater than or equal to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . This is stated in the CTS Bases. ITS SR 3.8.1.4 will continue to ensure that sufficient fuel is available for the DG to perform this safety function, as this is also stated in the ITS Bases. Also, this San Onofre Unit 2 and 3 Page 11 of 15 Attachment 1, Volume 11, Rev. 0, Page 59 of 437

Attachment 1, Volume 11, Rev. 0, Page 60 of 437 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES-OPERATING change is acceptable because these 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. The program provides for the evaluation of changes to ensure the Bases are properly controlled. Furthermore, the original intent of CTS SR 3.8.1.4 has not changed. This change is designated as a less restrictive removal of detail change because details are being moved from the Technical Specifications to the ITS Bases.

LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) CTS 3.8.1 Required Actions A.2 and B.4, contain a second Completion Time to restore the affected AC electrical source within 17 days from discovery of failure to meet the LCO. ITS 3.8.1 ACTION A and ACTION B, which provide the actions for the same Conditions of CTS 3.8.1 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 AC electrical sources within 17 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 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 San Onofre Unit 2 and 3 Page 12 of 15 Attachment 1, Volume 11, Rev. 0, Page 60 of 437

Attachment 1, Volume 11, Rev. 0, Page 61 of 437 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES-OPERATING 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 AC electrical source to be restored 17 days from discovery of failure to meet the LCO.

L02 (Category 4 - Relaxation of Required Action) CTS 3.8.1 ACTION F provides the actions when the Required Actions and associated Completion Time of Condition A, B, C, D, or E is not met. It requires the unit to be in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . ITS 3.8.1 ACTION F provides the actions to be taken under the same conditions. However, it 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 . Furthermore, the Required Action to be in MODE 4 is modified by a Note which states LCO 3.0.4.a is not applicable when entering MODE 4. This changes the CTS by eliminating the requirement for the unit to be in MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months and only requires the unit to be in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The purpose of CTS 3.8.1 ACTION F is to place the unit in a condition where the LCO is not applicable. The proposed change, which is consistent with TSTF-422, allows the plant end state to conclude at MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months versus MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . This change is based on a topical report, CE NPSD-01186 (approved by NRC on July 17, 2001), which justified a modified end state for some TS allowed outage time requirements of which the AC electrical sources is one. The topical report demonstrates through probabilistic and deterministic safety evaluations that the proposed end states represent a condition of equal or lower risk than the original end states. Preventing plant challenges during shutdown conditions has been, and continues to be, an important aspect of ensuring safe operation of the plant. Past events demonstrate that risk of core damage associated with entry into, and operation San Onofre Unit 2 and 3 Page 13 of 15 Attachment 1, Volume 11, Rev. 0, Page 61 of 437

Attachment 1, Volume 11, Rev. 0, Page 62 of 437 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES-OPERATING in, shutdown cooling is not negligible and should be considered when a plant is required to shutdown. Therefore, the Technical Specifications should encourage plant operation in the steam generator heat removal mode whenever practical, and require reliance on shutdown cooling only when it is a risk beneficial alternative to other actions.

The Note which modifies ITS 3.8.1 Required Action F.2 prohibits entry into the end state Mode of Applicability during startup using the provisions of LCO 3.0.4.a. The purpose of this Note is to provide assurance that entry into the end state Mode of Applicability during startup is not made without the appropriate risk assessment. Entry into the end state Mode of Applicability during startup will still be allowed under the provisions of LCO 3.0.4.b. This is acceptable because LCO 3.0.4.b allows entry only after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

Details of the risk assessment are provided in the Bases for LCO 3.0.4.b.

SONGS will adopt the end states proposed in TSTF-422 and will perform a risk assessment in accordance with 10 CFR 50.65(a)(4) when using the end states regardless of whether maintenance is being performed. The risk assessment will follow Regulatory Guide 1.182, Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants, which endorses NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Section 11 guidance for implementation of 10 CFR 50.65(a)(4). SONGS will also follow the industry-developed implementation guidance, WCAP-16364-NP, Revision 0, "Implementation Guidance for Risk Informed Modification to Selected Required Action End States at Combustion Engineering NSSS Plants (TSTF-422)," November 2004.

This change is designated as less restrictive because it relaxes the end state from MODE 5 to MODE 4.

L03 (Category 5 - Deletion of Surveillance Requirement) CTS SR 3.8.1.15 is a hot restart test and requires verifying the DG starts, achieves a specified voltage and frequency within 9.4 seconds, maintains a specified steady state voltage and frequency, and "operates for 5 minutes." ITS SR 3.8.1.15 contains the same requirements for the DG hot restart test except it does not require the DG to operate for 5 minutes after starting and achieving steady state voltage and frequency. This changes the CTS by eliminating the requirement to operate the DG for 5 minutes.

The purpose of CTS SR 3.8.1.15 is to demonstrate that the diesel engine restarts from a hot condition, such as subsequent to shutdown from normal surveillances, and achieves the required voltage and frequency within 9.4 seconds. The 9.4 second time is derived from the requirements of the accident analysis to respond to a design basis large break LOCA. CTS SR 3.8.1.15 contains a requirement for the DG to operate for 5 minutes. This requirement is not included in ITS SR 3.8.1.15. Operation of the DG for 5 minutes is not required to demonstrate the diesel engine restarts from a hot condition and achieves the required voltage and frequency within the time requirements assumed in the accident analysis.

San Onofre Unit 2 and 3 Page 14 of 15 Attachment 1, Volume 11, Rev. 0, Page 62 of 437

Attachment 1, Volume 11, Rev. 0, Page 63 of 437 DISCUSSION OF CHANGES ITS 3.8.1, AC SOURCES-OPERATING Therefore, deletion of the requirement that the DG operates for 5 minutes is acceptable. This change is designated as less restrictive because a requirement in the SR has been eliminated from the ITS that is included in the CTS.

San Onofre Unit 2 and 3 Page 15 of 15 Attachment 1, Volume 11, Rev. 0, Page 63 of 437

Attachment 1, Volume 11, Rev. 0, Page 64 of 437 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 64 of 437

Attachment 1, Volume 11, Rev. 0, Page 65 of 437 U2/U3 CTS AC Sources - Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating LCO 3.8.1 LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System,

3

b. Two diesel generators (DGs) each capable of supplying one train of the onsite Class 1E AC Electrical Power Distribution System, and

[ c. Automatic load sequencers for Train A and Train B. ] 4 Applicability APPLICABILITY: MODES 1, 2, 3, and 4.

ACTIONS

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

LCO 3.0.4.b is not applicable to DGs.

CONDITION REQUIRED ACTION COMPLETION TIME ACTION A 2 A. One [required] offsite A.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months circuit inoperable. [required] OPERABLE 2 offsite circuit. AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND A.2 Declare required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from with no offsite power discovery of no offsite available inoperable when power to one train its redundant required concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)

AND 1

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Attachment 1, Volume 11, Rev. 0, Page 66 of 437 U2/U3 CTS AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 2

A.3 Restore [required] offsite 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months circuit to OPERABLE status.

2 ACTION B B. One [required] DG B.1 Perform SR 3.8.1.1 for the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 2

inoperable. OPERABLE [required]

offsite circuit(s). AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND B.2 Declare required feature(s) 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from supported by the inoperable discovery of DG inoperable when its Condition B redundant required concurrent with feature(s) is inoperable. inoperability of redundant required feature(s)

AND B.3.1 Determine OPERABLE [24] hours 2 DG(s) is not inoperable due 1 to common cause failure.

OR 2

B.3.2 Perform SR 3.8.1.2 for [24] hours OPERABLE DG(s). 1 AND 14 days 8

B.4 Restore [required] DG to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 2 OPERABLE status.

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Attachment 1, Volume 11, Rev. 0, Page 67 of 437 U2/U3 CTS AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME 2

ACTION C C. Two [required] offsite C.1 Declare required feature(s) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from circuits inoperable. inoperable when its discovery of redundant required Condition C feature(s) is inoperable. concurrent with inoperability of redundant required feature(s)

AND C.2 Restore one [required] 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 2 offsite circuit to OPERABLE status.

ACTION D D. One [required] offsite --------------------NOTE------------------- 2 circuit inoperable. Enter applicable Conditions and Required Actions of LCO 3.8.9, AND "Distribution Systems - Operating,"

when Condition D is entered with no 2

One [required] DG AC power source to any train.

inoperable. ------------------------------------------------

D.1 Restore [required] offsite 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 2 circuits to OPERABLE status.

OR 2

D.2 Restore [required] DG to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status.

ACTION E E. Two [required] DGs E.1 Restore one [required] DG 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 2 inoperable. to OPERABLE status.

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Attachment 1, Volume 11, Rev. 0, Page 68 of 437 U2/U3 CTS AC Sources - Operating 3.8.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. ------------NOTE------------ F.1 Restore [required] [12] hours ]

[ This Condition may be [automatic load sequencer]

deleted if the unit design to OPERABLE status.

is such that any sequencer failure mode will only affect the ability of the associated DG to 4 power its respective safety loads following a loss of offsite power independent of, or coincident with, a Design Basis Event.

One [required]

[automatic load sequencer] inoperable.

ACTION F G. Required Action and G.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 4 associated Completion F

F Time of Condition A, B, AND C, D, E, or [F] not met. 4 12 4

G.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months TSTF-422 G or G

ACTION G 4 2 H. Three or more [required] H.1 Enter LCO 3.0.3. Immediately AC sources inoperable.

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

LCO 3.0.4.a is not applicable when entering MODE 4.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY TSTF-SR 3.8.1.1 SR 3.8.1.1 Verify correct breaker alignment and indicated 7 days 425-A power availability for each [required] offsite circuit. 2 In accordance with the Surveillance Frequency Control Program 1

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Attachment 1, Volume 11, Rev. 0, Page 69 of 437 U2/U3 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.2 SR 3.8.1.2 ------------------------------NOTES-----------------------------

1. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.

2. [ A modified DG start involving idling and 2 gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer. When modified start procedures

3. An automatic voltage are not used, the time, voltage, and frequency regulator (AVR) is only required to be tested once tolerances of SR 3.8.1.7 must be met. ] 2 10 per two Surveillance ---------------------------------------------------------------------

intervals.

TSTF-Verify each DG starts from standby conditions and 31 days 425-A 4576 achieves steady state voltage [3740] V and 4161

[4580] V, and frequency [58.8] Hz and 2

[61.2] Hz. 59.7 SR 3.8.1.3 SR 3.8.1.3 ------------------------------NOTES----------------------------- In accordance with the

1. DG loadings may include gradual loading as Surveillance Frequency Control Program recommended by the manufacturer.

2. Momentary transients outside the load range do not invalidate this test.

3. This Surveillance shall be conducted on only one DG at a time.

4. This SR shall be preceded by and immediately follow without shutdown a successful

5. An automatic voltage regulator (AVR) is only required to be performance of SR 3.8.1.2 or SR 3.8.1.7. 10 tested once per two ---------------------------------------------------------------------

Surveillance intervals.

TSTF-Verify each DG is synchronized and loaded, and 31 days 425-A operates for 60 minutes at a load [4500] kW and 2

[5000] kW.

4700 4450 TSTF-SR 3.8.1.4 SR 3.8.1.4 Verify each day tank [and engine mounted tank] 31 days 2 425-A contains [220] gal of fuel oil. 5 a fuel oil level 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of DG operation at full load plus 10%

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Attachment 1, Volume 11, Rev. 0, Page 70 of 437 U2/U3 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY TSTF-SR 3.8.1.5 SR 3.8.1.5 Check for and remove accumulated water from each [31] days 425-A day tank [and engine mounted tank]. 2 TSTF-SR 3.8.1.6 SR 3.8.1.6 Verify the fuel oil transfer system operates to [92] days 425-A

[automatically] transfer fuel oil from storage tank[s] 2 to the day tank [and engine mounted tank]. 2 In accordance with the Surveillance Frequency Control Program SR 3.8.1.7 SR 3.8.1.7 -------------------------------NOTE------------------------------

All DG starts may be preceded by an engine prelube period.

TSTF-425-A Verify each DG starts from standby condition and 184 days achieves: 9.4

a. In [10] seconds, voltage [3740] V and frequency [58.8] Hz and 4161 4576 59.7 2

b. Steady state voltage [3740] V and [4580] V, and frequency [58.8] Hz and [61.2] Hz.

59.7 S

SR 3.8.1.8 SR 3.8.1.8 -------------------------------NOTE------------------------------ 11 1.

[ This Surveillance shall not normally be performed 2 in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an

2. Testing to satisfy this assessment determines the safety of the plant is SR shall include actual automatic and manual maintained or enhanced. Credit may be taken for 2

transfer to at least one unplanned events that satisfy this SR. ] 11 alternate offsite circuit.

The other alternate offsite circuit may be TSTF-verified by overlapping [ Verify [automatic [and] manual] transfer of AC [18] months ] 425-A circuit tests.

power sources from the normal offsite circuit to each 2 alternate [required] offsite circuit.

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Attachment 1, Volume 11, Rev. 0, Page 71 of 437 U2/U3 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.9 SR 3.8.1.9 ------------------------------NOTES-----------------------------

1. [ This Surveillance shall not normally be 2 performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

2. If performed with the DG synchronized with offsite power, it shall be performed at a power within the power factor [0.9]. However, if grid conditions do not 6 factor limit permit, the power factor limit is not required to be met. Under this condition the power factor In accordance with the

3. An automatic voltage shall be maintained as close to the limit as Surveillance Frequency regulator (AVR) is only required to be tested practicable. ] Control Program 10 once each Surveillance ---------------------------------------------------------------------

interval during the performance of TSTF-SR 3.8.1.9, SR 3.8.1.10, Verify each DG rejects a load greater than or equal [18] months 425-A or SR 3.8.1.19. to its associated single largest post-accident load and:

a. Following load rejection, the frequency is

[63] Hz, 4 66.75

b. Within [3] seconds following load rejection, the 2

voltage is [3740] V and [4580] V, and 4161 4576

c. Within [3] seconds following load rejection, the 4

frequency is [58.8] Hz and [61.2] Hz.

59.7 1

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SURVEILLANCE FREQUENCY SR 3.8.1.10 SR 3.8.1.10 ------------------------------NOTES-----------------------------

1. [ This Surveillance shall not normally be 2 performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

within the power

2. If performed with DG synchronized with offsite factor limit power, it shall be performed at a power factor 6

[0.9]. However, if grid conditions do not

3. An automatic voltage permit, the power factor limit is not required to regulator (AVR) is only be met. Under this condition the power factor required to be tested once each Surveillance shall be maintained as close to the limit as interval during the practicable. ] 10 2

performance of ---------------------------------------------------------------------

SR 3.8.1.9, SR 3.8.1.10, or SR 3.8.1.19. TSTF-Verify each DG does not trip, and voltage is [18] months 425-A 5450 maintained [5000] V during and following a load 2 rejection of [4500] kW and [5000] kW.

4450 In accordance with the 4700 Surveillance Frequency Control Program 1

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Attachment 1, Volume 11, Rev. 0, Page 73 of 437 U2/U3 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.11 SR 3.8.1.11 ------------------------------NOTES-----------------------------

1. All DG starts may be preceded by an engine prelube period.

2. This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

TSTF-Verify on an actual or simulated loss of offsite power [18] months 425-A signal:

a. De-energization of emergency buses,

b. Load shedding from emergency buses, In accordance with the Surveillance Frequency

c. DG auto-starts from standby condition and: Control Program and resets the 4.16 kV 1. Energizes permanently connected loads bus undervoltage relay logic in [10] seconds, 9 2

2. Energizes auto-connected shutdown 9 loads through [automatic load sequencer],

3. Maintains steady state voltage [3740] V 9 2 and [4580] V, 4576 4161

4. Maintains steady state frequency 9 2

3 [58.8] Hz and [61.2] Hz, and 59.7

5. Supplies permanently connected [and 9 4 auto-connected] shutdown loads for 5 minutes.

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Attachment 1, Volume 11, Rev. 0, Page 74 of 437 U2/U3 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.12 SR 3.8.1.12 ------------------------------NOTES-----------------------------

12

1. [ All DG starts may be preceded by an engine 2 prelube period.

12

2. This Surveillance shall not normally be performed in MODE 1 or 2. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be In accordance with the Surveillance Frequency taken for unplanned events that satisfy this SR. Control Program TSTF-Verify on an actual or simulated Engineered Safety [18] months ] 425-A Feature (ESF) actuation signal each DG auto-starts from standby condition and:

9.4

a. In [10] seconds after auto-start and during tests, achieves voltage [3740] V and frequency [58.8] Hz, 4161 59.7 2

b. Achieves steady state voltage [3740] V and

[4580] V and frequency [58.8] Hz and 4576 [61.2] Hz, and 59.7

c. Operates for 5 minutes, .

d. Permanently connected loads remain energized from the offsite power system, and 12

e. Emergency loads are energized [or auto-connected through the automatic load sequencer] from the offsite power system.

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Attachment 1, Volume 11, Rev. 0, Page 75 of 437 U2/U3 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.13 SR 3.8.1.13 -------------------------------NOTE------------------------------

[ This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be 14 performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR. ] 2 Verify each DG's noncritical automatic trips are [18] months TSTF-425-A bypassed on [actual or simulated loss of voltage signal on the emergency bus concurrent with an 2 actual or simulated ESF actuation signal].

In accordance with the Surveillance Frequency Control Program 1

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Attachment 1, Volume 11, Rev. 0, Page 76 of 437 U2/U3 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.14 SR 3.8.1.14 ------------------------------NOTES-----------------------------

1. Momentary transients outside the load and power factor ranges do not invalidate this test.

2. This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish 15 OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

2 3. If performed with DG synchronized with offsite 15 power, it shall be performed at a power factor 6

[0.9]. However, if grid conditions do not within the power factor limit permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

TSTF-Verify each DG operates for 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months s: [18] months 425-A

a. For [2] hours loaded [5250] kW and

[5500] kW and 5170 4935 2

b. For the remaining hours of the test loaded

[4500] kW and [5000] kW.

4450 In accordance with the 4700 Surveillance Frequency Control Program 1

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Attachment 1, Volume 11, Rev. 0, Page 77 of 437 U2/U3 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.15 SR 3.8.1.15 ------------------------------NOTES-----------------------------

1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated [2] hours loaded [4500] kW 2

and [5000] kW.

4450 4700 Momentary transients outside of load range do not invalidate this test.

2. All DG starts may be preceded by an engine prelube period.

TSTF-Verify each DG starts and achieves: [18] months 425-A 4161 9.4

a. In [10] seconds, voltage [3740] V and frequency [58.8] Hz and 4161 4576 2 59.7

b. Steady state voltage [3740] V and [4580] V, and frequency [58.8] Hz and [61.2] Hz.

59.7 In accordance with the Surveillance Frequency SR 3.8.1.16 SR 3.8.1.16 -------------------------------NOTE------------------------------ Control Program This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR.

TSTF-Verify each DG: [18] months 425-A

a. Synchronizes with offsite power source while loaded with emergency loads upon a simulated restoration of offsite power,

b. Transfers loads to offsite power source, and

c. Returns to ready-to-load operation.

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Attachment 1, Volume 11, Rev. 0, Page 78 of 437 U2/U3 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.17 SR 3.8.1.17 -------------------------------NOTE------------------------------

[ This Surveillance shall not normally be performed 2 in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

Credit may be taken for unplanned events satisfy this SR.

TSTF-425-A Verify, with a DG operating in test mode and [18] months ]

connected to its bus, an actual or simulated ESF actuation signal overrides the test mode by:

a. Returning DG to ready-to-load operation and

[ b. Automatically energizing the emergency load from offsite power. ] In accordance with the Surveillance Frequency Control Program SR 3.8.1.18 SR 3.8.1.18 -------------------------------NOTE------------------------------

[ This Surveillance shall not normally be performed 16 in MODE 1, 2, 3, or 4. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR. ] 2 timing of its timer setting Verify interval between each sequenced load block [18] months TSTF-425-A 13 is within +/- [10% of design interval] for each or +/- 2.5 seconds, emergency [and shutdown] load sequencer. whichever is greater, 2 with the exception of programmed the 5 second load time interval group, whose criteria is -0.5, +2.5 seconds, 1

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Attachment 1, Volume 11, Rev. 0, Page 79 of 437 U2/U3 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.19 SR 3.8.1.19 ------------------------------NOTES-----------------------------

1. All DG starts may be preceded by an engine prelube period.

2. This Surveillance shall not normally be performed in MODE 1, 2, 3, or 4. However, portions of the Surveillance may be performed to reestablish OPERABILITY provided an

3. An automatic voltage assessment determines the safety of the plant regulator (AVR) is only required to be tested is maintained or enhanced. Credit may be once each Surveillance taken for unplanned events that satisfy this SR. 10 interval during the ---------------------------------------------------------------------

performance of SR 3.8.1.9, SR 3.8.1.10, TSTF-or SR 3.8.1.19. Verify on an actual or simulated loss of offsite power [18] months 425-A signal in conjunction with an actual or simulated ESF actuation signal:

a. De-energization of emergency buses, In accordance with the Surveillance Frequency

b. Load shedding from emergency buses, Control Program

c. DG auto-starts from standby condition and:

1. energizes permanently connected loads and resets the 4.16 kV in [10] seconds, bus undervoltage 7 relay logic

2. energizes auto-connected emergency loads through [load sequencer], 7 the programmed time interval

3. achieves steady state voltage [3740] V and [4580] V, 2 4161 4576

4. achieves steady state frequency

[58.8] Hz and [61.2] Hz, and 59.7

5. supplies permanently connected [and auto-connected] emergency loads for

[5] minutes.

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Attachment 1, Volume 11, Rev. 0, Page 80 of 437 U2/U3 CTS AC Sources - Operating 3.8.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.1.20 SR 3.8.1.20 -------------------------------NOTE------------------------------

All DG starts may be preceded by an engine prelube period.

TSTF-Verify, when started simultaneously from standby 10 years 425-A condition, each DG achieves:

9.4

a. In [10] seconds, voltage [3740] V and In accordance with the frequency [58.8] Hz and 4161 Surveillance Frequency 59.7 Control Program 2

b. Steady state voltage [3740] V and [4580] V, and frequency [58.8] Hz and [61.2] Hz.

4576 59.7 1

CEOG STS San Onofre -- Draft 3.8.1-16 Amendment XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 80 of 437

Attachment 1, Volume 11, Rev. 0, Page 81 of 437 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES-OPERATING

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. 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 bracketed ISTS LCO 3.8.1.c and ACTION F are being deleted. SONGS "sequencer" is a series of timer relays which loads required systems on the emergency bus on timed intervals in load blocks. It is not a solid state system or self contained therefore, inoperabilities of the "sequencer" only affects the systems associated with individual load blocks. Therefore, SONGS will not add the automatic load sequencer to the LCO or ACTIONS in the ITS. In addition, due to the deletion, subsequent ACTIONS have been renumbered.

5. ISTS SR 3.8.1.4 states, "Verify each day tank [and engine mounted tank] contains

[220] gal of fuel oil." The bracketed value of fuel oil volume is calculated on a plant-specific basis. The licensing basis for this bracketed value is to maintain sufficient fuel oil volume to operate the DG at full load plus 10% for greater than or equal to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . Proposed ITS SR 3.8.1.4 does not specify the gallons of fuel oil but does specify that each day tank contains a fuel level greater than or equal to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of DG operation at full load plus 10 %. The proposed change is necessary because the US Environmental Protection Agency (EPA) has more stringent standards for diesel fuel. Since the processing required to reduce sulfur in ultra lower sulfur diesel (ULSD) also reduces the aromatics content and density of diesel fuel, this also results in a reduction of volumetric energy content (BTU/gallon). Furthermore, the requirements on diesel fuel oil may continue to change in the future and the addition of additives to compensate for the issues associated with ULSD may further affect the volumetric energy content (and, as a result, the stored diesel fuel oil volume requirements). These changes would result in future license amendments to revise the fuel oil volume. In order to facilitate the expeditious revision of the fuel oil volume requirement when needed and to avoid the unnecessary expenditure of licensee and NRC resources to prepare and review future license amendment requests that simply revise the volume, the proposed change places the requirement to have stored fuel oil sufficient to support 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of DG operation at full load plus 10 % in the Technical Specifications with the equivalent numerical volume under licensee control in the Technical Specification Bases. This change is based on TSTF-501 which was approved for ISTS SR 3.8.3.1. ISTS SR 3.8.3.1 contained the volumetric requirements for a 7 day supply of fuel.

6. The ISTS contains a Note in SRs 3.8.1.9, 3.8.1.10, and 3.8.1.14 which states, "If performed with DG synchronized with offsite power, it shall be performed at a power factor [0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as San Onofre Unit 2 and 3 Page 1 of 5 Attachment 1, Volume 11, Rev. 0, Page 81 of 437

Attachment 1, Volume 11, Rev. 0, Page 82 of 437 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES-OPERATING close to the limit as practicable." This Note is being changed by replacing "at a power factor [0.9]" with "within the power factor limit," to be consistent with the SONGS CTS allowances. Currently, the power factor Note is not contained in the SONGS CTS, but is contained in the CTS Bases. The ITS will include the Note, but it will not specify a specific power factor value (e.g., 0.9) in the Notes to the Surveillances.

The specific power factor value (as represented by inductive loading-kVARS) is included in the ITS Bases for the three Surveillances and will therefore be controlled under the Technical Specifications Bases Control Program. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This type of change was previously approved in the ITS conversions for Davis-Besse, Monticello Nuclear Generating Plant, James A. FitzPatrick Nuclear Power Plant, Quad Cities Units 1 and 2, Dresden Units 1 and 2, and LaSalle Units 1 and 2.

7. ISTS SR 3.8.1.19.c.1 was changed to add to energizes permanently connected loads, "and resets the 4.16kV bus undervoltage relay logic" and the actual name of the load sequencer was changed to "programmed time interval load sequence" in ISTS SR 3.9.1.19.c.2 to specifically list what is required in the SONGS ITS and to use the specific SONGS nomenclature.

8. ISTS 3.8.1 Required Action B.4 Completion Time is being changed from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 14 days. This change is based on an augmented analysis using the methodology set forth in the ASME Code for Operation and Maintenance of Nuclear Power Plants which provides a series of deterministic and probabilistic justifications and supports continued operations in Condition B for a period that should not exceed 14 days.

This change was approved by the NRC in License Amendment 141 and 133, as documented in the NRC Safety Evaluation dated 9/27/98 (Adams Accession No. ML022000066).

9. ISTS SR 3.8.1.11.c.2 requirement that the SR verify auto-connected loads are energized through the automatic load sequencer is being deleted for the SONGS ITS. ISTS SR 3.8.1.11.c.5 also ensure the auto-connected loads are energized for 5 minutes. Since SONGS does not have auto-connected shutdown loads, the RG 1.9 requirements for sequencing of auto-connected shutdown loads do not apply.

Due to this deletion, subsequent parts of this SR have been renumbered. In addition, ISTS SR 3.8.1.11.c.1 was changed to add to energizes permanently connected loads, "and resets the 4.16kV bus undervoltage relay logic" to specifically list what is required in the SONGS ITS.

10. A Note is being added to ISTS SRs 3.8.1.2, 3.8.1.3, 3.8.1.9, 3.8.1.10, and 3.8.1.19 to modify the SRs for the SONGS automatic voltage regulator (AVR). SONGS DGs each have two AVRs, and each is capable of performing the required AVR function.

The SONGS CTS provides allowances such that SONGS is only required to test an AVR once every two Surveillance intervals for SRs 3.8.1.2 and 3.8.1.3; and only required to test an AVR during performance of SR 3.8.1.9, SR 3.8.1.10, or SR 3.8.1.19 for each Surveillance interval (i.e., every 24 months).

11. A Note is being added to ISTS SR 3.8.1.8 to modify the SR to adopt SONGS current allowance to verify the transfer of AC power sources from the normal offsite circuit to the alternate offsite circuit via actual transfer for one alternate offsite circuit and via overlapping circuit tests for the other alternate circuit. SONGS has two alternate San Onofre Unit 2 and 3 Page 2 of 5 Attachment 1, Volume 11, Rev. 0, Page 82 of 437

Attachment 1, Volume 11, Rev. 0, Page 83 of 437 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES-OPERATING offsite circuits, both of which are qualified to meet the LCO requirements. This Note allows only one of the two to be tested similar to the SR requirements, with the other circuit tested by overlapping circuit tests. This is allowed by the CTS and is being maintained in the ITS upgrade submittal.

12. ISTS SR 3.8.1.12.d and e require, following the DG start on an ESF actuation signal, for the permanently connected loads to remain powered from the offsite power system and the emergency loads to be energized or autoconnected through the load sequencer from the offsite power system. These two requirements have not been included in the SONGS ITS. The SONGS design includes individual timer relays, as discussed in JFD 4, not a load sequencer. The loads that are sequenced have single timers that are based not on what the power source is, but if power is available. Therefore, the timers are adequately tested in other SRs, like SR 3.8.1.18 and SR 3.18.1.19. In addition, the permanently connected loads are not deenergized on an ESF signal, thus there is no reason to confirm that they are not inadvertently removed from service. As stated in the ISTS Bases, the requirement to verify the connection of permanent and autoconnected loads is intended to satisfactorily show the relationship of these loads to the DG loading logic. Since the timers are already adequately tested as part of other SRs, there is no reason to include it in this specific SR. This is also consistent with current Technical Specifications, which does not include these two requirements.

Furthermore, since these two requirements are not being added, there is no reason to include ISTS SR 3.8.1.12 Note 2. This Note precludes the entire SR from being performed in MODE 1 or 2. However, the remaining portions of the SR (a, b, and c) can safely be performed in MODE 1. The three criteria to be met are performed at least every six months as required by ITS SR 3.8.1.7. As stated in the ISTS Bases, the reason for the Note is that during operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and unit safety systems. However, ESF signal generation is performed in accordance with SRs in ITS SR 3.3.6.2 every 184 days, and the DG is started and operated in accordance with SR 3.8.1.7 every 184 days. Neither of these tests have similar restrictions, nor does this ITS SR 3.8.1.12 test cause any of the problems noted in the ISTS SR 3.8.1.12 Bases. Therefore, this Note has not been adopted in the SONGS ITS. This is also consistent with the CTS, which does not have this restrictive Note. Due to this deletion, the word "NOTES" has been changed to "NOTE" and the number for the first Note has been deleted.

13. ISTS SR 3.8.1.18 requires verifying the interval between each sequenced load block is within + 10% of design interval. ISTS requires verifying the timing of each sequenced load block is within its timer setting + 10% or + 2.5 seconds, whichever is greater, with the exception of the 5 second load group, whose criteria is -0.5, +2.5 seconds. This change was previously approved by the NRC as documented in the NRC Safety Evaluation for Units 2 and 3 Amendments 169 and 160, respectively, dated September 1, 2000 (ADAMS Accession No. ML00374807).

14. ISTS SR 3.8.1.13 requires verifying each DG's non-critical automatic trips are bypassed on an actual or simulated ESF actuation signal. The SR includes a Note precluding performing this Surveillance in MODE 1 or 2. This Note has not been San Onofre Unit 2 and 3 Page 3 of 5 Attachment 1, Volume 11, Rev. 0, Page 83 of 437

Attachment 1, Volume 11, Rev. 0, Page 84 of 437 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES-OPERATING included in the ITS SR 3.8.1.13. The bypassing of these trip is currently tested as part of every fourth performance of ITS SR 3.3.6.2, which verifies the subgroup relays every 184 days. During this required instrument Surveillance, the DG is not being operated as part of the required instrument Surveillance (but it may be running to perform a DG related Surveillance), but it is not connected to the 1E bus.

The ISTS Bases for the SR states that the Note is not required if performance of the SR will not render any safety system or component inoperable, will not cause any perturbation to any electrical distribution systems that could result in a challenge to steady state operation or plant safety systems, and will not cause or result in an anticipated operational occurrences (AOO) with attendant challenge to plant safety systems. Since the DG is not connected to the 1E bus, it does not affect the electrical distribution systems. Furthermore, since it is performed concurrent with the routinely performed subgroup relay Surveillance required every 184 days by SR 3.3.6.2 (it is just an additional data collection requirement after the ESF signal is generated), it does not result in any safety system or component being inoperable or cause an AOO. Therefore, this Note is not needed in the SONGS ITS. This is also consistent with the CTS, which does not include this Note.

15. ISTS SR 3.8.1.14 requires performance of a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months DG run. The SR includes a Note (Note 2) precluding this SR from being performed in MODE 1 or 2. This Note has not been included in the ITS SR 3.8.1.14. The SR is performed with the DG paralleled with offsite power. The ISTS Bases for the SR says the reason for the Note is because performing the SR while critical could cause perturbations to the electrical distribution system that could challenge continued steady state operation and unit safety systems. However, another DG Surveillance performed on a monthly basis (e.g., SR 3.8.1.3) requires the DG to be paralleled with offsite power.

The only difference between this Surveillance and SR 3.8.1.3 is the duration of the test. SONGS Transformer and generator sizes and impedances were selected considering voltage and short circuit current. Contributions from the running DG, offsite power system, and operating loads on the Class 1E electrical power system were all considered. Calculations demonstrate that Class 1E voltages and short circuit currents remain within equipment design limits when the DG is connected to the bus (as required to perform the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months run Surveillance). If an actuation signal occurs while the DG is paralleled to offsite, the DG is automatically taken out of the test mode. Furthermore, the DG output breaker is opened, which results in the DG governor being reset to 60Hz so that when the DG breaker recloses, the proper speed and voltage are generated. Therefore, this Note is not needed in the SONGS ITS, since the DG can safely be run while paralleled with offsite power.

This is also consistent with the CTS, which does not include this Note, and SONGS currently performs this SR on line. In addition, due to this deletion, the subsequent Note has been renumbered.

16. ISTS SR 3.8.1.18, requires verification of the intervals between each load block is within the limit. The SR includes a Note precluding this SR from being performed in MODE 1 or 2. This Note has not been included in the ITS SR 3.8.1.18. ITS SR 3.8.1.18 has been modified as discussed in JFD 13 to require the timing of each sequenced load block is within its timer setting limits. The SONGS design includes individual timer relays, as discussed in JFD 4, not a load sequencer. The loads that are sequenced have single timers that are based not on what the power source is, but if power is available. This SR is routinely performed while on line during San Onofre Unit 2 and 3 Page 4 of 5 Attachment 1, Volume 11, Rev. 0, Page 84 of 437

Attachment 1, Volume 11, Rev. 0, Page 85 of 437 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1, AC SOURCES-OPERATING performance of the ESFAS instrument logic testing required by ITS 3.3.6. During this normal instrument test, the DG is not being operated, thus it is not paralleled with offsite power. The ISTS Bases for the SR states that the Note is not required if performance of the SR will not render any safety system or component inoperable, will not cause any perturbation to any electrical distribution systems that could result in a challenge to steady state operation or plant safety systems, and will not cause or result in an anticipated operational occurrences (AOO) with attendant challenge to plant safety systems. Since the DG is not operated nor paralleled, it does not affect the electrical distribution systems. Furthermore, it does not result in any safety system or component being inoperable or cause an AOO. Therefore, this Note is not needed in the SONGS ITS. This is also consistent with the CTS, which does not include this Note.

San Onofre Unit 2 and 3 Page 5 of 5 Attachment 1, Volume 11, Rev. 0, Page 85 of 437

Attachment 1, Volume 11, Rev. 0, Page 86 of 437 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 86 of 437

Attachment 1, Volume 11, Rev. 0, Page 87 of 437 AC Sources - Operating B 3.8.1 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.1 AC Sources - Operating BASES BACKGROUND The unit Class 1E Electrical Power Distribution System AC sources consist of the offsite power sources (preferred power sources, normal and alternate(s)), and the onsite standby power sources (Train A and Train B diesel generators (DGs)). As required by 10 CFR 50, Appendix A, GDC 17 (Ref. 1), the design of the AC electrical power system provides independence and redundancy to ensure an available source of power to the Engineered Safety Feature (ESF) systems.

The onsite Class 1E AC Distribution System is divided into redundant load groups (trains) so that the loss of any one group does not prevent the minimum safety functions from being performed. Each train has connections to two preferred offsite power sources and a single DG.

1 Offsite power is supplied to the unit switchyard(s) from the transmission nine network by [two] transmission lines. From the switchyard(s), two reserve electrically and physically separated circuits provide AC power, through

[step down station auxiliary transformers], to the 4.16 kV ESF buses. A 2 detailed description of the offsite power network and the circuits to the Class 1E ESF buses is found in the FSAR, Chapter [8] (Ref. 2).

U An offsite circuit consists of all breakers, transformers, switches, interrupting devices, cabling, and controls required to transmit power from the offsite transmission network to the onsite Class 1E ESF bus or buses.

Certain required unit loads are returned to service in a predetermined sequence in order to prevent overloading the transformer supplying offsite power to the onsite Class 1E Distribution System. Within [1 minute] after 77 2 the initiating signal is received, all automatic and permanently connected seconds programmed time loads needed to recover the unit or maintain it in a safe condition are interval load sequence returned to service via the load sequencer. 1 G002 and G003 The onsite standby power source for each 4.16 kV ESF bus is a A04 dedicated DG. DGs [11] and [12] are dedicated to ESF buses [11] 2 and [12], respectively. A DG starts automatically on a safety injection (SI)

A06 signal (i.e., low pressurizer pressure or high containment pressure signals) or on an [ESF bus degraded voltage or undervoltage signal].

After the DG has started, it will automatically tie to its respective bus after offsite power is tripped as a consequence of ESF bus undervoltage or 1

CEOG STS San Onofre -- Draft B 3.8.1-1 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 87 of 437

Attachment 1, Volume 11, Rev. 0, Page 88 of 437 AC Sources - Operating B 3.8.1 BASES BACKGROUND (continued) degraded voltage, independent of or coincident with an SI signal. The DGs will also start and operate in the standby mode without tying to the (except load centers and High Pressure Safety ESF bus on an SI signal alone. Following the trip of offsite power, [a 2

Injection (HPSI) pumps) sequencer/an undervoltage signal] strips nonpermanent loads from the selected ESF bus. When the DG is tied to the ESF bus, loads are then programmed time interval sequentially connected to its respective ESF bus by the automatic load 1 load sequence sequencer. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading the DG by automatic load application.

In the event of a loss of preferred power, the ESF electrical loads are automatically connected to the DGs in sufficient time to provide for safe reactor shutdown and to mitigate the consequences of a Design Basis Accident (DBA) such as a loss of coolant accident (LOCA).

77 seconds Certain required unit loads are returned to service in a predetermined sequence in order to prevent overloading the DG in the process. Within

[1] minute after the initiating signal is received, all loads needed to 2 recover the unit or maintain it in a safe condition are returned to service.

Ratings for Train A and Train B DGs satisfy the requirements of 4700 Regulatory Guide 1.9 (Ref. 3). The continuous service rating of each DG 2 is [7000] kW with [10]% overload permissible for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months in any 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period. The ESF loads that are powered from the 4.16 kV ESF buses are listed in Reference 2.

U 1 APPLICABLE The initial conditions of DBA and transient analyses in the FSAR, SAFETY Chapter [6] (Ref. 4) and Chapter [15] (Ref. 5), assume ESF systems are 2 ANALYSES OPERABLE. The AC electrical power sources are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to ESF systems so that the fuel, Reactor Coolant System (RCS), and containment design limits are not exceeded.

These limits are discussed in more detail in the Bases for Section 3.2, Power Distribution Limits; Section 3.4, Reactor Coolant System (RCS);

and Section 3.6, Containment Systems.

The OPERABILITY of the AC electrical power sources is consistent with the initial assumptions of the accident analyses and is based upon meeting the design basis of the unit. This results in maintaining at least one train of the onsite or offsite AC sources OPERABLE during accident conditions in the event of:

1 CEOG STS San Onofre -- Draft B 3.8.1-2 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 88 of 437

Attachment 1, Volume 11, Rev. 0, Page 89 of 437 AC Sources - Operating B 3.8.1 BASES APPLICABLE SAFETY ANALYSES (continued)

a. An assumed loss of all offsite power or all onsite AC power and

b. A worst case single failure.

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

LCO Two qualified circuits between the offsite transmission network and the onsite Class 1E Electrical Power Distribution System and separate and independent DGs for each train ensure availability of the required power to shut down the reactor and maintain it in a safe shutdown condition after an anticipated operational occurrence (AOO) or a postulated DBA.

U Qualified offsite circuits are those that are described in the FSAR and are 1 part of the licensing basis for the unit.

[ In addition, one required automatic load sequencer per train must be 3

OPERABLE. ]

Each offsite circuit must be capable of maintaining rated frequency and voltage, and accepting required loads during an accident, while connected to the ESF buses.

[ Offsite circuit #1 consists of Safeguards Transformer B, which is supplied INSERT 1 from Switchyard Bus B, and is fed through breaker 52-3 powering the 2

ESF transformer XNB01, which, in turn, powers the #1 ESF bus through its normal feeder breaker. Offsite circuit #2 consists of the Startup Transformer, which is normally fed from the Switchyard Bus A, and is fed through breaker PA 0201 powering the ESF transformer, which, in turn, powers the #2 ESF bus through its normal feeder breaker. ]

Each DG must be capable of starting, accelerating to rated speed and

, and resetting voltage, and connecting to its respective ESF bus on detection of bus 1 the 4.16 kV bus undervoltage. This will be accomplished within [10] seconds. Each DG 2 undervoltage must also be capable of accepting required loads within the assumed relay logic loading sequence intervals, and continue to operate until offsite power can be restored to the ESF buses. These capabilities are required to be met from a variety of initial conditions such as DG in standby with the engine hot and DG in standby with the engine at ambient conditions.

Additional DG capabilities must be demonstrated to meet required Surveillances, e.g., capability of the DG to revert to standby status on an ECCS signal while operating in parallel test mode.

1 CEOG STS San Onofre -- Draft B 3.8.1-3 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 89 of 437

Attachment 1, Volume 11, Rev. 0, Page 90 of 437 B 3.8.1 2

INSERT 1 The normal preferred power source (Offsite circuit #1) for each unit is Reserve Auxiliary Transformers XR1 and XR2 for the specific unit. XR1 feeds one 4.16 kV ESF bus (Train A) A04 and XR2 feeds the other 4.16 kV ESF bus (Train B) A06 of the onsite Class 1E AC distribution system for each unit. In addition, when a unit is in MODE 3 or 4 with the units main generator isophase bus links removed, the units Main Transformer and the Unit Auxiliary Transformer XU1 may be used as the normal preferred power source (Offsite circuit #1). The alternate preferred power source (Offsite circuit #2) is the other units Reserve Auxiliary Transformers XR1 and XR2, or the other units Main Transformer and Unit Auxiliary Transformer XU1 (if the other unit is in MODE 3 or 4) through the train oriented 4.16 KV ESF bus cross-ties between the two units. The 4.16 kV ESF bus alignment in the other unit determines which transformer(s) serves as the alternate preferred power source. If the 4.16 kV ESF bus in the other unit is aligned to the Reserve Auxiliary Transformer (XR1 or XR2), then that transformer is the required alternate preferred power source. If the 4.16 kV ESF bus in the other unit is aligned to the Main Transformer and Unit Auxiliary Transformer (XU1), then that transformer is the required alternate preferred power source.

Insert Page B 3.8.1-3 Attachment 1, Volume 11, Rev. 0, Page 90 of 437

Attachment 1, Volume 11, Rev. 0, Page 91 of 437 AC Sources - Operating B 3.8.1 BASES LCO (continued)

Proper sequencing of loads, [including tripping of nonessential loads,] is a 2 required function for DG OPERABILITY.

The AC sources in one train must be separate and independent (to the extent possible) of the AC sources in the other train. For the DGs, separation and independence are complete.

For the offsite AC sources, separation and independence are to the extent practical. A circuit may be connected to more than one ESF bus, with fast transfer capability to the other circuit OPERABLE, and not 1 violate separation criteria. A circuit that is not connected to an ESF bus is required to have OPERABLE fast transfer interlock mechanisms to at 1 least two ESF buses to support OPERABILITY of that circuit.

APPLICABILITY The AC sources [and sequencers] are required to be OPERABLE in 1 MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of AOOs or abnormal transients and

b. Adequate core cooling is provided and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

The AC power requirements for MODES 5 and 6 are covered in LCO 3.8.2, "AC Sources - Shutdown."

ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable DG.

There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable DG 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.

A.1 To ensure a highly reliable power source remains with the one offsite circuit inoperable, it is necessary to verify the OPERABILITY of the remaining required offsite circuit on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met.

However, if a second required circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition C, for two offsite circuits inoperable, is entered.

1 CEOG STS San Onofre -- Draft B 3.8.1-4 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 91 of 437

Attachment 1, Volume 11, Rev. 0, Page 92 of 437 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

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

The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that 4

the remaining OPERABLE motor or turbine driven auxiliary feedwater pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.

A.2 Required Action A.2, which only applies if the train cannot be powered from an offsite source, is intended to provide assurance that an event coincident with a single failure of the associated DG will not result in a complete loss of safety function of critical redundant required features.

INSERT 2 These features are powered from the redundant AC electrical power train. 7 This includes motor driven auxiliary feedwater pumps. Single train systems, such as turbine driven auxiliary feedwater pumps, may not be included.

The Completion Time for Required Action A.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a. The train has no offsite power supplying its loads and

b. A required feature on the other train is inoperable.

If at any time during the existence of Condition A (one offsite circuit inoperable) a redundant required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

1 CEOG STS San Onofre -- Draft B 3.8.1-5 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 92 of 437

Attachment 1, Volume 11, Rev. 0, Page 93 of 437 B 3.8.1 7

INSERT 2 These redundant required features are those that are assumed to function to mitigate an accident, coincident with a loss of offsite power, in the safety analyses, such as the Emergency Core Cooling System and Auxiliary Feedwater System. These redundant required features do not include monitoring requirements, such as Post Accident Monitoring and Remote Shutdown.

Insert Page B 3.8.1-5 Attachment 1, Volume 11, Rev. 0, Page 93 of 437

Attachment 1, Volume 11, Rev. 0, Page 94 of 437 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

Discovering no offsite power to one train of the onsite Class 1E Electrical Power Distribution System coincident with one or more inoperable required support or supported features, or both, that are associated with the other train that has offsite power, results in starting the Completion Times for the Required Action. Twenty-four hours is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

The remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to Train A and Train B of the onsite Class 1E Distribution System. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the component OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

A.3 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition A for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With one offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the unit safety systems. In this Condition, however, the remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite Class 1E Distribution System.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

B.1 To ensure a highly reliable power source remains with an inoperable DG, it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must then be entered.

1 CEOG STS San Onofre -- Draft B 3.8.1-6 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 94 of 437

Attachment 1, Volume 11, Rev. 0, Page 95 of 437 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

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

The turbine driven auxiliary feedwater pump is only required to be considered a redundant required feature, and, therefore, required to be determined OPERABLE by this Required Action, if the design is such that 4 the remaining OPERABLE motor or turbine driven auxiliary feedwater pump(s) is not by itself capable (without any reliance on the motor driven auxiliary feedwater pump powered by the emergency bus associated with the inoperable diesel generator) of providing 100% of the auxiliary feedwater flow assumed in the safety analysis.

B.2 Required Action B.2 is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a complete loss of safety function of critical systems. These features are 7 redundant required features designed with redundant safety related trains. This includes motor driven auxiliary feedwater pumps. Single train systems, such as turbine driven auxiliary feedwater pumps, are not included. Redundant required feature failures consist of inoperable features with a train, redundant to the train that has an inoperable DG.

The Completion Time for Required Action B.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a. An inoperable DG exists and

b. A required feature on the other train is inoperable.

If at any time during the existence of this Condition (one DG inoperable) a required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

1 CEOG STS San Onofre -- Draft B 3.8.1-7 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 95 of 437

Attachment 1, Volume 11, Rev. 0, Page 96 of 437 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

Discovering one required DG inoperable coincident with one or more inoperable required support or supported features, or both, that are associated with the OPERABLE DG, results in starting the Completion Time for the Required Action. Four hours from the discovery of these events existing concurrently, is acceptable because it minimizes risk while allowing time for restoration before subjecting the unit to transients associated with shutdown.

In this Condition, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

B.3.1 and B.3.2 Required Action B.3.1 provides an allowance to avoid unnecessary testing of OPERABLE DGs. If it can be determined that the cause of the inoperable DG does not exist on the OPERABLE DG, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on other the 3

DG(s), the other DG(s) would be declared inoperable upon discovery and 3 Condition E of LCO 3.8.1 would be entered. Once the failure is repaired, the common cause failure no longer exists and Required Action B.3.1 is satisfied. If the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DG(s), performance of SR 3.8.1.2 suffices to 3 provide assurance of continued OPERABILITY of that DG.

In the event the inoperable DG is restored to OPERABLE status prior to 2

completing either B.3.1 or B.3.2, the [plant corrective action program] will continue to evaluate the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months constraint imposed while in Condition B.

2 According to Generic Letter 84-15 (Ref. 7), [24] hours is reasonable to confirm that the OPERABLE DG(s) is not affected by the same problem 1 as the inoperable DG.

1 CEOG STS San Onofre -- Draft B 3.8.1-8 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 96 of 437

Attachment 1, Volume 11, Rev. 0, Page 97 of 437 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

B.4 INSERT 3 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in 1 Condition B for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

In Condition B, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity 3 14 day and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

C.1 and C.2 Required Action C.1, which applies when two offsite circuits are inoperable, is intended to provide assurance that an event with a features coincident single failure will not result in a complete loss of redundant 7

required safety functions. The Completion Time for this failure of INSERT 4 redundant required features is reduced to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from that allowed for one train without offsite power (Required Action A.2). The rationale for the reduction to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is that Regulatory Guide 1.93 (Ref. 6) allows a Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for two required offsite circuits inoperable, based upon the assumption that two complete safety trains are OPERABLE. When a concurrent redundant required feature failure exists, this assumption is not the case, and a shorter Completion Time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is appropriate. These features are powered from redundant AC safety trains. This includes motor driven auxiliary feedwater pumps.

Single train features, such as turbine driven auxiliary pumps, are not included in the list.

The Completion Time for Required Action C.1 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." In this Required Action, the Completion Time only begins on discovery that both:

a. All required offsite circuits are inoperable and

b. A required feature is inoperable.

1 CEOG STS San Onofre -- Draft B 3.8.1-9 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 97 of 437

Attachment 1, Volume 11, Rev. 0, Page 98 of 437 B 3.8.1 1

INSERT 3 An augmented analysis using the methodology set forth in Reference 12 provides a series of deterministic and probabilistic justifications and supports continued operations in Condition B for a period that should not exceed 14 days.

7 INSERT 4 These redundant required features are those that are assumed to function to mitigate an accident, coincident with a loss of offsite power, in the safety analyses, such as the Emergency Core Cooling System and Auxiliary Feedwater System. The redundant required features do not include monitoring requirements, such as Post Accident Monitoring and Remote Shutdown.

Insert Page B 3.8.1-9 Attachment 1, Volume 11, Rev. 0, Page 98 of 437

Attachment 1, Volume 11, Rev. 0, Page 99 of 437 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

If at any time during the existence of Condition C (two offsite circuits inoperable) and a required feature becomes inoperable, this Completion Time begins to be tracked.

According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition C for a period that should not exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This level of degradation means that the offsite electrical power system does not have the capability to effect a safe shutdown and to mitigate the effects of an accident; however, the onsite AC sources have not been degraded. This level of degradation generally corresponds to a total loss of the immediately accessible offsite power sources.

Because of the normally high availability of the offsite sources, this level of degradation may appear to be more severe than other combinations of two AC sources inoperable that involve one or more DGs inoperable.

However, two factors tend to decrease the severity of this level of degradation:

a. The configuration of the redundant AC electrical power system that remains available is not susceptible to a single bus or switching failure and

b. The time required to detect and restore an unavailable offsite power source is generally much less than that required to detect and restore an unavailable onsite AC source.

With both of the required offsite circuits inoperable, sufficient onsite AC sources are available to maintain the unit in a safe shutdown condition in the event of a DBA or transient. In fact, a simultaneous loss of offsite AC sources, a LOCA, and a worst case single failure were postulated as a part of the design basis in the safety analysis. Thus, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time provides a period of time to effect restoration of one of the offsite circuits commensurate with the importance of maintaining an AC electrical power system capable of meeting its design criteria.

According to Reference 6, with the available offsite AC sources, two less than required by the LCO, operation may continue for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . If two offsite sources are restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , unrestricted operation may continue. If only one offsite source is restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , power operation continues in accordance with Condition A.

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Attachment 1, Volume 11, Rev. 0, Page 100 of 437 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

D.1 and D.2 Pursuant to LCO 3.0.6, the Distribution System ACTIONS would not be entered even if all AC sources to it were inoperable resulting in de-energization. Therefore, the Required Actions of Condition D are modified by a Note to indicate that when Condition D is entered with no AC source to any train, the Conditions and Required Actions for LCO 3.8.9, "Distribution Systems - Operating," must be immediately entered. This allows Condition D to provide requirements for the loss of one offsite circuit and one DG without regard to whether a train is de-energized. LCO 3.8.9 provides the appropriate restrictions for a de-energized train.

According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition D for a period that should not exceed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

In Condition D, individual redundancy is lost in both the offsite electrical power system and the onsite AC electrical power system. Since power system redundancy is provided by two diverse sources of power, however, the reliability of the power systems in this Condition may appear higher than that in Condition C (loss of both required offsite circuits). This difference in reliability is offset by the susceptibility of this power system configuration to a single bus or switching failure. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

E.1 With Train A and Train B DGs inoperable, there are no remaining standby AC sources. Thus, with an assumed loss of offsite electrical power, insufficient standby AC sources are available to power the minimum required ESF functions. Since the offsite electrical power system is the only source of AC power for this level of degradation, the risk associated with continued operation for a short time could be less than that associated with an immediate controlled shutdown (the immediate shutdown could cause grid instability, which could result in a total loss of AC power). Since any inadvertent generator trip could also result in a total loss of offsite AC power, however, the time allowed for continued operation is severely restricted. The intent here is to avoid the risk associated with an immediate controlled shutdown and to minimize the risk associated with this level of degradation.

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Attachment 1, Volume 11, Rev. 0, Page 101 of 437 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued)

According to Regulatory Guide 1.93 (Ref. 6), with both DGs inoperable, operation may continue for a period that should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

[ F.1 The sequencer(s) is an essential support system to [both the offsite circuit and the DG associated with a given ESF bus]. [Furthermore, the sequencer is on the primary success path for most major AC electrically powered safety systems powered from the associated ESF bus.]

Therefore, loss of an [ESF bus sequencer] affects every major ESF system in the [division]. The [12] hour Completion Time provides a period of time to correct the problem commensurate with the importance of 3

maintaining sequencer OPERABILITY. This time period also ensures that the probability of an accident (requiring sequencer OPERABILITY) occurring during periods when the sequencer is inoperable is minimal.

This Condition is preceded by a Note that allows the Condition to be deleted if the unit design is such that any sequencer failure mode will only affect the ability of the associated DG to power its respective safety loads under any conditions. Implicit in this Note is the concept that the Condition must be retained if any sequencer failure mode results in the inability to start all or part of the safety loads when required, regardless of power availability, or results in overloading the offsite power circuit to a safety bus during an event, thereby causing its failure. Also implicit in the Note, is that the Condition is not applicable to any train that does not have a sequencer. ]

F G.1 and G.2 3 If the inoperable AC electrical power sources cannot be restored to plant risk is minimized OPERABLE status within the required Completion Time, the unit must be TSTF-brought to a MODE in which the LCO does not apply. To achieve this 422 4

status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to 12 MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

INSERT 5 TSTF-422 1

CEOG STS San Onofre -- Draft B 3.8.1-12 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 101 of 437

Attachment 1, Volume 11, Rev. 0, Page 102 of 437 B 3.8.1 TSTF-422 INSERT 5 Remaining within the Applicability of the LCO is acceptable because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 7). In MODE 5, it is likely that 1 14 increased plant maintenance activities (particularly those involving the switchyard) will make the plant more susceptible to loss of offsite power events. In MODE 4 there are more accident mitigation systems available and there is more redundancy and diversity in core heat removal mechanisms than in MODE 5. However, voluntary entry into MODE 5 may be made as it is also an acceptable low-risk state.

Required Action G.2 is modified by a Note that states that LCO 3.0.4.a is not 3 F

applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met. However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

Insert Page B 3.8.1-12 Attachment 1, Volume 11, Rev. 0, Page 102 of 437

Attachment 1, Volume 11, Rev. 0, Page 103 of 437 AC Sources - Operating B 3.8.1 BASES ACTIONS (continued) G 3

H.1 Condition H corresponds to a level of degradation in which all redundancy 3 in the AC electrical power supplies has been lost. At this severely degraded level, any further losses in the AC electrical power system will cause a loss of function. Therefore, no additional time is justified for continued operation. The unit is required by LCO 3.0.3 to commence a controlled shutdown.

SURVEILLANCE The AC sources are designed to permit inspection and testing of all REQUIREMENTS important areas and features, especially those that have a standby function, in accordance with 10 CFR 50, Appendix A, GDC 18 (Ref. 8).

Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions). The SRs for demonstrating the OPERABILITY of the DGs are in accordance with the recommendations of Regulatory Guide 1.9 (Ref. 3), Regulatory Guide 1.108 (Ref. 9), and Regulatory Guide 1.137 (Ref. 10), as addressed in the FSAR.

U 1 Where the SRs discussed herein specify voltage and frequency 4297 tolerances, the following is applicable. The minimum steady state output INSERT 6 voltage of [3740] V is 90% of the nominal 4160 V output voltage. This 2 value, which is specified in ANSI C84.1-1982 (Ref. 11), allows for voltage 1 4160 3744 drop to the terminals of 4000 V motors whose minimum operating voltage is specified as 90% or 3600 V. It also allows for voltage drops to motors This minimum voltage requirement also and other equipment down through the 120 V level where minimum 8 ensures that adequate operating voltage is also usually specified as 80% of name plate rating.

voltage is provided 4576 The specified maximum steady state output voltage of [4756] V is equal 2 4160 to the maximum operating voltage specified for 4000 V motors. It ensures that for a lightly loaded distribution system, the voltage at the terminals of 59.7 4160 4000 V motors is no more than the maximum rated operating voltages.

The specified minimum and maximum frequencies of the DG are 58.8 Hz The upper and 61.2 Hz, respectively. These values are equal to +/- 2% of the 60 Hz frequency limit is + 1 is nominal frequency and are derived from the recommendations given in Regulatory Guide 1.9 (Ref. 3).

The lower frequency limit is equal to -0.5% of the 60 Hz nominal frequency and is based on maintaining acceptable high pressure safety injection system performance as assumed in the accident analyses.

1 CEOG STS San Onofre -- Draft B 3.8.1-13 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 103 of 437

Attachment 1, Volume 11, Rev. 0, Page 104 of 437 B 3.8.1 1

INSERT 6 above the maximum reset voltage of the 4.16kV bus undervoltage relays. Achieving a voltage at or above 4297 V ensures that the LOVS/SDVS/DGVSS relay logic will reset allowing sequencing of the ESF loads on to the ESF bus if one or more ESF actuation signals is present.

Insert Page B 3.8.1-13 Attachment 1, Volume 11, Rev. 0, Page 104 of 437

Attachment 1, Volume 11, Rev. 0, Page 105 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

For Unit 2, Bus 3A04 or Bus SR 3.8.1.1 3A06 is required when unit crosstie breaker 3A0416 or 3A0603, respectively, is used This SR assures proper circuit continuity for the offsite AC electrical to provide a source of AC power supply to the onsite distribution network and availability of offsite power. For Unit 3, Bus 2A04 AC electrical power. The breaker alignment verifies that each breaker is or Bus 2A06 is required when unit crosstie breaker 2A0417 or in its correct position to ensure that distribution buses and loads are 2A0619, respectively, is used connected to their preferred power source, and that appropriate to provide a source of AC independence of offsite circuits is maintained. The 7 day Frequency is 1 power.

adequate since breaker position is not likely to change without the TSTF-INSERT 7 operator being aware of it and because its status is displayed in the 425-A control room.

SR 3.8.1.2 and SR 3.8.1.7 These SRs help to ensure the availability of the standby electrical power supply to mitigate DBAs and transients and to maintain the unit in a safe shutdown condition.

To minimize the wear on moving parts that do not get lubricated when the engine is not running, these SRs are modified by a Note (Note 1 for SR 3.8.1.2 and Note for SR 3.8.1.7) to indicate that all DG starts for these Surveillances may be preceded by an engine prelube period and followed by a warmup period prior to loading by an engine prelube period. 11 For the purposes of SR 3.8.1.2 and SR 3.8.1.7 testing, the DGs are started from standby conditions. Standby conditions for a DG mean the diesel engine coolant and oil are being continuously circulated and temperature is being maintained consistent with manufacturer recommendations.

2 s

[ In order to reduce stress and wear on diesel engines, the DG 11 manufacturers recommend a modified start in which the starting speed of DGs is limited, warmup is limited to this lower speed, and the DGs are gradually accelerated to synchronous speed prior to loading. This is the SR 3.8.1.2 intent of Note 2, which is only applicable when such modified start 5 procedures are recommended by the manufacturer.

SR 3.8.1.7 requires that, at a 184 day Frequency, the DG starts from TSTF-425-A 9.4 standby conditions and achieves required voltage and frequency within 3

10 seconds. The 10 second start requirement supports the assumptions of the design basis LOCA analysis in the FSAR, Chapter [15] (Ref. 5). ] 2 U 1 1

CEOG STS San Onofre -- Draft B 3.8.1-14 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 105 of 437

Attachment 1, Volume 11, Rev. 0, Page 106 of 437 B 3.8.1 TSTF-425-A INSERT 7 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 4 appropriate choice of Frequency in the Surveillance Requirement.

Insert Page B 3.8.1-14 Attachment 1, Volume 11, Rev. 0, Page 106 of 437

Attachment 1, Volume 11, Rev. 0, Page 107 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 9.4 The 10 second start requirement is not applicable to SR 3.8.1.2 (see Note 2) when a modified start procedure as described above is used. If a modified start is not used, 10 second start requirement of SR 3.8.1.7 3

applies. 9.4 Since SR 3.8.1.7 requires a 10 second start, it is more restrictive than SR 3.8.1.2, and it may be performed in lieu of SR 3.8.1.2.

In addition to the SR requirements, the time for the DG to reach steady state operation, unless the modified DG start method is employed, is periodically monitored and the trend evaluated to identify degradation of INSERT 8 governor and voltage regulator performance.

INSERT 9 The 31 day Frequency for SR 3.8.1.2 is consistent with Regulatory TSTF-Guide 1.9 (Ref. 3). The 184 day Frequency for SR 3.8.1.7 is a reduction 425-A in cold testing consistent with Generic Letter 84-15 (Ref. 7). These Frequencies provide adequate assurance of DG OPERABILITY, while minimizing degradation resulting from testing.

3 SR 3.8.1.3 This Surveillance verifies that the DGs are capable of synchronizing with the offsite electrical system and accepting loads greater than or equal to the equivalent of the maximum expected accident loads. A minimum run time of 60 minutes is required to stabilize engine temperatures, while minimizing the time that the DG is connected to the offsite source.

Although no power factor requirements are established by this SR, the DG is normally operated at a power factor between [0.8 lagging] and 9 INSERT 10

[1.0]. The 0.8 value is the design rating of the machine, while [1.0] is an INSERT 11 operational limitation [to ensure circulating currents are minimized]. The TSTF-31 day Frequency for this Surveillance is consistent with Regulatory 425-A Guide 1.9 (Ref. 3).

five This SR is modified by four Notes. Note 1 indicates that diesel engine 1 runs for this Surveillance may include gradual loading, as recommended by the manufacturer, so that mechanical stress and wear on the diesel engine are minimized. Note 2 states that momentary transients because of changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the limit will not invalidate the test. Note 3 indicates that this Surveillance should be conducted on only one DG at a time in order to avoid common cause failures that might result from offsite circuit or grid perturbations. Note 4 stipulates a prerequisite requirement for performance of this SR. A successful DG start must precede this test 3

INSERT 12 to credit satisfactory performance.

1 CEOG STS San Onofre -- Draft B 3.8.1-15 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 107 of 437

Attachment 1, Volume 11, Rev. 0, Page 108 of 437 B 3.8.1 3

INSERT 8 The Automatic Voltage Regulator (AVR) is discussed in SR 3.8.1.2 Note 3. The AVR is an integral part of the DG; however, each DG has 2 AVRs that are 100%

redundant to each other. Only one AVR is required to be OPERABLE and can be in service at any one time. To ensure OPERABILITY of each AVR, the AVRs must have been in service during the performance of SR 3.8.1.2 and SR 3.8.1.3 within the last two Surveillances intervals. Based on the design of the AVR, its intended function and the maintenance history, testing the AVR every second Surveillance will assure the AVRs are capable of performing their intended function.

TSTF-Frequencies for 425-A each INSERT 9 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 4 appropriate choice of Frequency in the Surveillance Requirement.

9 INSERT 10 the surveillance is performed with DG kVAR output that offsite power system conditions permit during testing without exceeding equipment ratings (i.e., without creating an overvoltage condition on the ESF buses, over excitation condition on the ESF buses, over excitation condition in the generator, or overloading the DG main feeder). The kVAR loading requirement during this test is met, and the equipment ratings are not exceeded, when the DG kVAR output is increased such that:

a. kVAR is > 3000 and < 3200;

b. the excitation current is > 3.8 A and < 4.0 A for all EDGs except 3G003 and

> 5.1 A and < 5.5 A for EDG 3G003;

c. the ESF bus voltage is > 4530 V and < 4550 V; or

d. DG feeder current is > 730 A and < 750 A.

This method of establishing kVAR loading ensures that, in addition to verifying the load carrying capability (kW) of the diesel engine, the reactive power (kVAR) and voltage regulation capability of the generator is verified to the extent practicable, consistent with the recommendations of Regulatory Guide 1.9 (Ref. 3).

Insert Page B 3.8.1-15a Attachment 1, Volume 11, Rev. 0, Page 108 of 437

Attachment 1, Volume 11, Rev. 0, Page 109 of 437 B 3.8.1 TSTF-425-A INSERT 11 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 4 appropriate choice of Frequency in the Surveillance Requirement.

3 INSERT 12 The Automatic Voltage Regulator (AVR) is discussed in Note 5. The AVR is an integral part of the DG; however, each DG has 2 AVRs that are 100% redundant to each other. Only one AVR is required to be OPERABLE and can be in service at any one time. To ensure OPERAABILITY of each AVR, the AVRs must have been in service during the performance of SR 3.8.1.2 and SR 3.8.1.3 within the last two Surveillances intervals. Based on the design of the AVR, its intended function and the maintenance history, testing the AVR every second Surveillance will assure the AVRs are capable of performing their intended function.

Insert Page B 3.8.1-15b Attachment 1, Volume 11, Rev. 0, Page 109 of 437

Attachment 1, Volume 11, Rev. 0, Page 110 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.4 This SR provides verification that the level of fuel oil in the day tank [and 3

engine mounted tank] is at or above the level at which fuel oil is automatically added. The level is expressed as an equivalent volume in gallons, and is selected to ensure adequate fuel oil for a minimum of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of DG operation at full load plus 10%. 3 INSERT 13 The 31 day Frequency is adequate to assure that a sufficient supply of INSERT 14 TSTF-fuel oil is available, since low level alarms are provided and unit operators 425-A would be aware of any large uses of fuel oil during this period.

SR 3.8.1.5 Microbiological fouling is a major cause of fuel oil degradation. There are numerous bacteria that can grow in fuel oil and cause fouling, but all must have a water environment in order to survive. Removal of water from the 3

fuel oil day [and engine mounted] tanks once every [31] days eliminates TSTF-425-A the necessary environment for bacterial survival. This is the most effective means of controlling microbiological fouling. In addition, it eliminates the potential for water entrainment in the fuel oil during DG operation. Water may come from any of several sources, including condensation, ground water, rain water, contaminated fuel oil, and from breakdown of the fuel oil by bacteria. Frequent checking for and removal of accumulated water minimizes fouling and provides data regarding the watertight integrity of the fuel oil system. The Surveillance Frequencies TSTF-are established by Regulatory Guide 1.137 (Ref. 10). This SR is for 425-A INSERT 14 preventive maintenance. The presence of water does not necessarily represent failure of this SR provided the accumulated water is removed during the performance of this Surveillance.

SR 3.8.1.6 This Surveillance demonstrates that each required fuel oil transfer pump operates and transfers fuel oil from its associated storage tank to its associated day tank. This is required to support continuous operation of standby power sources. This Surveillance provides assurance that the fuel oil transfer pump is OPERABLE, the fuel oil piping system is intact, the fuel delivery piping is not obstructed, and the controls and control systems for automatic fuel transfer systems are OPERABLE.

1 CEOG STS San Onofre -- Draft B 3.8.1-16 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 110 of 437

Attachment 1, Volume 11, Rev. 0, Page 111 of 437 B 3.8.1 3

INSERT 13 The fuel oil level equivalent to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of DG operation at full load plus 10% is 389 gallons or 31.5 inches, when calculated in accordance with References 10 and 15.

TSTF-425-A INSERT 14 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 4 appropriate choice of Frequency in the Surveillance Requirement.

Insert Page B 3.8.1-16 Attachment 1, Volume 11, Rev. 0, Page 111 of 437

Attachment 1, Volume 11, Rev. 0, Page 112 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

[ The Frequency for this SR is variable, depending on individual system design, with up to a [92] day interval. The [92] day Frequency corresponds to the testing requirements for pumps as contained in the TSTF-ASME Code (Ref. 12); however, the design of fuel transfer systems is 425-A INSERT 15 such that pumps will operate automatically or must be started manually in order to maintain an adequate volume of fuel oil in the day [and engine mounted] tanks during or following DG testing. In such a case, a 31 day Frequency is appropriate. Since proper operation of fuel transfer systems is an inherent part of DG OPERABILITY, the Frequency of this SR should be modified to reflect individual designs. ]

SR 3.8.1.7 See SR 3.8.1.2.

[ SR 3.8.1.8

, via the train-aligned Transfer of each [4.16 kV ESF bus] power supply from the normal offsite 2 4.16 kV crosstie between Unit 2 and Unit 3, circuit to the alternate offsite circuit demonstrates the OPERABILITY of 1 the alternate circuit distribution network to power the shutdown loads.

The [18 month] Frequency of the Surveillance is based on engineering judgment, taking into consideration the unit conditions required to perform INSERT 15 the Surveillance, and is intended to be consistent with expected fuel cycle TSTF-lengths. Operating experience has shown that these components usually 425-A pass the SR when performed at the [18 month] Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

two Notes 1 This SR is modified by a Note. The reason for the Note is that during 3 operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system 1

CEOG STS San Onofre -- Draft B 3.8.1-17 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 112 of 437

Attachment 1, Volume 11, Rev. 0, Page 113 of 437 B 3.8.1 TSTF-425-A INSERT 15 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 4 appropriate choice of Frequency in the Surveillance Requirement.

Insert Page B 3.8.1-17 Attachment 1, Volume 11, Rev. 0, Page 113 of 437

Attachment 1, Volume 11, Rev. 0, Page 114 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.]

INSERT 16 3 SR 3.8.1.9 Each DG is provided with an engine overspeed trip to prevent damage to the engine. Recovery from the transient caused by the loss of a large load could cause diesel engine overspeed, which, if excessive, might result in a trip of the engine. This Surveillance demonstrates the DG load response characteristics and capability to reject the largest single load without exceeding predetermined voltage and frequency and while maintaining a specified margin to the overspeed trip. [For this unit, the 2 the motor-driven Auxiliary single load for each DG and its horsepower rating is as follows:] This Feedwater pump which has a nameplate rating of 800 HP. Surveillance may be accomplished by:

a. Tripping the DG output breaker with the DG carrying greater than or equal to its associated single largest post-accident load while paralleled to offsite power or while solely supplying the bus, or

b. Tripping its associated single largest post-accident load with the DG solely supplying the bus.

As required by IEEE-308 (Ref. 13), the load rejection test is acceptable if the increase in diesel speed does not exceed 75% of the difference between synchronous speed and the overspeed trip setpoint, or 15%

above synchronous speed, whichever is lower.

The time, voltage, and frequency tolerances specified in this SR are derived from Regulatory Guide 1.9 (Ref. 3) recommendations for 2

80%

response during load sequence intervals. The [3] seconds specified is 4

equal to 60% of a typical 5 second load sequence interval associated with 1 sequencing of the largest load. The voltage and frequency specified are INSERT 17 consistent with the design range of the equipment powered by the DG.

SR 3.8.1.9.a corresponds to the maximum frequency excursion, while SR 3.8.1.9.b and SR 3.8.1.9.c are steady state voltage and frequency values to which the system must recover following load rejection. The TSTF-INSERT 18 [18 month] Frequency is consistent with the recommendation of 425-A Regulatory Guide 1.108 (Ref. 9).

1 CEOG STS San Onofre -- Draft B 3.8.1-18 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 114 of 437

Attachment 1, Volume 11, Rev. 0, Page 115 of 437 B 3.8.1 1

INSERT 16 The reason for Note 2 is to ensure that the actual transfer (manual and automatic) from the normal offsite circuit to at least one of the alternate offsite circuits is satisfied by the test; however, testing on the other alternate offsite circuit may be verified by overlapping circuit tests. For each 4.16kV ESF bus (A04 or A06) this Surveillance Requirement may be satisfied by performing both a manual transfer and an auto-transfer from the normal offsite power source to at least one of the alternate offsite power sources. The tested source may then be credited as the required alternate offsite power source per LCO 3.8.1. This Surveillance may be satisfied for the remaining alternate offsite power source by performing a circuit functional test in addition to the transfer test above. This functional test shall be performed such that all components that are required to function for a successful manual or auto-transfer that were not included in the transfer tests above, are tested. This testing may include any series of sequential, overlapping, or total steps so that the entire manual and auto-transfer capability of the source is verified.

1 INSERT 17 Since SONGS specific analyses demonstrate the acceptability of overlapping load groups (i.e., adjacent load groups that start at the same time due to load sequence timer tolerance), the use of 80% of load sequence interval for voltage recovery is consistent with the requirements of Regulatory Guide 1.9 (Ref. 3)

TSTF-425-A INSERT 18 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 4 appropriate choice of Frequency in the Surveillance Requirement.

Insert Page B 3.8.1-18 Attachment 1, Volume 11, Rev. 0, Page 115 of 437

Attachment 1, Volume 11, Rev. 0, Page 116 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) three This SR is modified by two Notes. The reason for Note 1 is that during 3 operation with the reactor critical, performance of this SR could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

INSERT 19 Credit may be taken for unplanned events that satisfy this SR. Note 2 INSERT 20 ensures that the DG is tested under load conditions that are as close to 3 design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of [0.9]. This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note 2 allows the Surveillance to be conducted at a power factor other than [0.9]. These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to

[0.9] results in voltages on the emergency busses that are too high.

Under these conditions, the power factor should be maintained as close as practicable to [0.9] while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor of [0.9]

may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such cases, the power factor shall be maintained as close as practicable to

[0.9] without exceeding the DG excitation limits.

INSERT 21 3

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

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable: 4

a. Performance of the SR will not render any safety system or component inoperable, 1

CEOG STS San Onofre -- Draft B 3.8.1-19 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 116 of 437

Attachment 1, Volume 11, Rev. 0, Page 117 of 437 B 3.8.1 3

INSERT 19 requires the DG to operate within the power factor limit when synchronized with offsite power. However, this limit is not required to be met if the grid conditions do not permit, but the power factor must be maintained as close to the limit as practicable. In order to 3

INSERT 20

, testing is performed by rejecting an inductive load with kW and kVAR greater than or equal to the single largest post-accident load (683 kW, 369 kVAR). These test conditions are consistent with the power factor requirements of Regulatory Guide 1.9 (Ref. 3) and the recommendations of Information Notice 91-13 (Ref. 12).

3 INSERT 21 The Automatic Voltage Regulator (AVR) is discussed in Note 3. The AVR is an integral part of the DG; however, each DG has 2 AVRs that are 100% redundant to each other. Only one AVR is required to be OPERABLE and can be in service at any one time. To ensure OPERABILITY, each AVR must be in service during the performance of either SR 3.8.1.9, SR 3.8.1.10, or SR 3.8.1.19 each Surveillance interval. Based on the design of the AVR, its intended function and the maintenance history, the above specified Surveillances will assure the AVRs are capable of performing their intended function.

Insert Page B 3.8.1-19 Attachment 1, Volume 11, Rev. 0, Page 117 of 437

Attachment 1, Volume 11, Rev. 0, Page 118 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and 4

c. Performance of the SR or failure of the SR will not cause or result in an AOO with attendant challenge to plant safety systems.

SR 3.8.1.10 This Surveillance demonstrates the DG capability to reject a full load equal to 90% to 100% of 1 its continuous rating without overspeed tripping or exceeding the predetermined voltage limits.

The DG full load rejection may occur because of a system fault or inadvertent breaker tripping. This Surveillance ensures proper engine generator load response under the simulated test conditions. This test simulates the loss of the total connected load that the DG experiences following a full load rejection and verifies that the DG will not trip upon loss of the load. These acceptance criteria provide DG damage protection. While the DG is not expected to experience this transient during an event and continues to be available, this response ensures that the DG is not degraded for future application, including reconnection to the bus if the trip initiator can be corrected or isolated.

INSERT 22 The [18 month] Frequency is consistent with the recommendation of TSTF-Regulatory Guide 1.108 (Ref. 9) and is intended to be consistent with 425-A expected fuel cycle lengths.

three This SR is modified by two Notes. The reason for Note 1 is that during 3 operation with the reactor critical, performance of this SR could cause perturbation to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the 1

CEOG STS San Onofre -- Draft B 3.8.1-20 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 118 of 437

Attachment 1, Volume 11, Rev. 0, Page 119 of 437 B 3.8.1 TSTF-425-A INSERT 22 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 4 appropriate choice of Frequency in the Surveillance Requirement.

Insert Page B 3.8.1-20 Attachment 1, Volume 11, Rev. 0, Page 119 of 437

Attachment 1, Volume 11, Rev. 0, Page 120 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR. Note 2 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of [0.9]. This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note 2 allows the Surveillance to be conducted at a power 3 factor other than [0.9]. These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to INSERT 23 [0.9] results in voltages on the emergency busses that are too high.

Under these conditions, the power factor should be maintained as close as practicable to [0.9] while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor of [0.9]

may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such cases, the power factor shall be maintained as close as practicable to

[0.9] without exceeding the DG excitation limits.

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

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable: 4

a. Performance of the SR will not render any safety system or component inoperable,

b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and

c. Performance of the SR or failure of the SR will not cause or result in an AOO with attendant challenge to plant safety systems.

1 CEOG STS San Onofre -- Draft B 3.8.1-21 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 120 of 437

Attachment 1, Volume 11, Rev. 0, Page 121 of 437 B 3.8.1 3

INSERT 23 requires the DG to operate within the power factor limit when synchronized with offsite power. However, this limit is not required to be met if the grid conditions do not permit, but the power factor must be maintained as close to the limit as practicable. The DG is tested under inductive load conditions that are as close to design basis conditions as possible. Testing is performed with DG kVAR output that offsite power system conditions permit during testing without exceeding equipment ratings (i.e., without creating an overvoltage condition on the ESF buses, over excitation condition in the generator, or overloading the DG main feeder). The kVAR loading requirement during the test is met, and the equipment ratings are not exceeded, when the DG kVAR output is increased such that:

a. kVAR is 3000 and 3200;

b. the excitation current is 3.8 A and 4.0 A for all EDGs except 3G003 and 5.1 A and 5.5 A for EDG 3G003;

c. the ESF bus voltage is 4530 V and 4550 V; or

d. DG feeder current is 730 A and 750 A.

This method of establishing kVAR loading ensures that, in addition to verifying the full load rejection capability (kW) of the diesel engine, the reactive power rejection capability (kVAR) of the generator is verified to the extent practicable, consistent with the recommendations of Regulatory Guide 1.9 (Ref. 3) and Information Notice 91-13 (Ref. 12).

The Automatic Voltage Regulator (AVR) is discussed in Note 3. The AVR an integral part of the DG; however, each DG has 2 AVRs that are 100% redundant to each other. Only one AVR is required to be OPERABLE and can be in service at any one time. To ensure OPERABILITY, each AVR must be in service during the performance of either SR 3.8.1.9, SR 3.8.1.10, or SR 3.8.1.19 each Surveillance interval. Based on the design of the AVR, its intended function and the maintenance history, the above specified Surveillances will assure the AVRs are capable of performing their intended function.

Insert Page B 3.8.1-21 Attachment 1, Volume 11, Rev. 0, Page 121 of 437

Attachment 1, Volume 11, Rev. 0, Page 122 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) 9 3 SR 3.8.1.11 As required by Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(1), this 1 Surveillance demonstrates the as designed operation of the standby power sources during loss of the offsite source. This test verifies all selected actions encountered from the loss of offsite power, including shedding of the nonessential loads and energization of the emergency buses and 1 respective loads from the DG. It further demonstrates the capability of the DG to automatically achieve the required voltage and frequency within the specified time.

and undervoltage relay logic reset The DG auto-start time of [10] seconds is derived from requirements of 1 2 the accident analysis to respond to a design basis large break LOCA.

The Surveillance should be continued for a minimum of 5 minutes in order to demonstrate that all starting transients have decayed and stability has been achieved.

The requirement to verify the connection and power supply of permanent and auto-connected loads is intended to satisfactorily show the 3 relationship of these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, Emergency Core Cooling Systems (ECCS) injection valves are not desired to be stroked open, high pressure injection systems are not capable of being operated at full flow, or shutdown cooling (SDC) systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable.

This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The Frequency of [18 months] is consistent with the recommendations of TSTF-INSERT 24 Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(1), takes into 425-A consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

This SR is modified by two Notes. The reason for Note 1 is to minimize wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained 1

CEOG STS San Onofre -- Draft B 3.8.1-22 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 122 of 437

Attachment 1, Volume 11, Rev. 0, Page 123 of 437 B 3.8.1 TSTF-425-A INSERT 24 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 4 appropriate choice of Frequency in the Surveillance Requirement.

Insert Page B 3.8.1-22 Attachment 1, Volume 11, Rev. 0, Page 123 of 437

Attachment 1, Volume 11, Rev. 0, Page 124 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) consistent with manufacturer recommendations. The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems. This restriction from normally performing the 4 10

, 2, 3, Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes.

These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced 4 10

, 2, 3, when portions of the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment.

Credit may be taken for unplanned events that satisfy this SR.

[ SR 3.8.1.12 This Surveillance demonstrates that the DG automatically starts and a safety achieves the required voltage and frequency within the specified time injection

([10] seconds) from the design basis actuation signal (LOCA signal) and 3 1 9.4 operates for 5 minutes. The 5 minute period provides sufficient time to demonstrate stability. SR 3.8.1.12.d and SR 3.8.1.12.e ensure that 3

permanently connected loads and emergency loads are energized from the offsite electrical power system on an ESF signal without loss of offsite power.

The requirement to verify the connection of permanent and autoconnected loads is intended to satisfactorily show the relationship of 3 these loads to the DG loading logic. In certain circumstances, many of these loads cannot actually be connected or loaded without undue hardship or potential for undesired operation. For instance, ECCS injection valves are not desired to be stroked open, high pressure injection systems are not capable of being operated at full flow, or SDC systems performing a decay heat removal function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration 1

CEOG STS San Onofre -- Draft B 3.8.1-23 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 124 of 437

Attachment 1, Volume 11, Rev. 0, Page 125 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. 3 This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The Frequency of [18 months] takes into consideration unit conditions required to perform the Surveillance and is intended to be consistent with TSTF-INSERT 25 the expected fuel cycle lengths. Operating experience has shown that 425-A these components usually pass the SR when performed at the [18 month]

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

a the This SR is modified by two Notes. The reason for Note 1 is to minimize 3 wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations. The reason for Note 2 is that during operation with the reactor critical, performance of this Surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. This restriction from normally performing the 3 Surveillance in MODE 1 or 2 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes.

These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when portions of the Surveillance are performed in MODE 1 or . Risk insights or deterministic methods may be used for the assessment.

Credit may be taken for unplanned events that satisfy this SR. ]

1 CEOG STS San Onofre -- Draft B 3.8.1-24 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 125 of 437

Attachment 1, Volume 11, Rev. 0, Page 126 of 437 B 3.8.1 TSTF-425-A INSERT 25 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 4 appropriate choice of Frequency in the Surveillance Requirement.

Insert Page B 3.8.1-24 Attachment 1, Volume 11, Rev. 0, Page 126 of 437

Attachment 1, Volume 11, Rev. 0, Page 127 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.13 This Surveillance demonstrates that DG noncritical protective functions (e.g., high jacket water temperature) are bypassed on a loss of voltage 3 signal concurrent with an ESF actuation test signal. Noncritical automatic trips are all automatic trips except:

a. Engine overspeed;

b. Generator differential current;

-low

[ c. Low lube oil pressure; 2

d. High crankcase pressure; and 2

e. Start failure relay.]

The noncritical trips are bypassed during DBAs and provide an alarm on an abnormal engine condition. This alarm provides the operator with sufficient time to react appropriately. The DG availability to mitigate the DBA is more critical than protecting the engine against minor problems that are not immediately detrimental to emergency operation of the DG.

The [18 month] Frequency is based on engineering judgment, taking into consideration unit conditions required to perform the Surveillance, and is TSTF-intended to be consistent with expected fuel cycle lengths. Operating 425-A INSERT 26 experience has shown that these components usually pass the SR when performed at the [18 month] Frequency. Therefore, the Frequency was concluded to be acceptable from a reliability standpoint.

The SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required DG from service. This restriction from normally performing the Surveillance in MODE or is 3 further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or 1

CEOG STS San Onofre -- Draft B 3.8.1-25 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 127 of 437

Attachment 1, Volume 11, Rev. 0, Page 128 of 437 B 3.8.1 TSTF-425-A INSERT 26 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 4 appropriate choice of Frequency in the Surveillance Requirement.

Insert Page B 3.8.1-25 Attachment 1, Volume 11, Rev. 0, Page 128 of 437

Attachment 1, Volume 11, Rev. 0, Page 129 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) enhanced when the Surveillance is performed in MODE 1 or 2. Risk 3

insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.

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

The above MODE restrictions may be deleted if it can be demonstrated to 4 the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable:

a. Performance of the SR will not render any safety system or component inoperable,

b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and

c. Performance of the SR or failure of the SR will not cause or result in an AOO with attendant challenge to plant safety systems.

9 3 SR 3.8.1.14 Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(3), requires 1 TSTF-demonstration once per 18 months that the DGs can start and run 425-A continuously at full load capability for an interval of not less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , 105% to [2] hours of which is at a load equivalent to 110% of the continuous duty 2 1 rating and the remainder of the time at a load equivalent to the continuous 1 90% to 100% of duty rating of the DG. The DG starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelubricating and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.

The load band is provided to avoid routine overloading of the DG.

Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY.

The [18 month] Frequency is consistent with the recommendations of INSERT 27 Regulatory Guide 1.108 (Ref. 7), paragraph 2.a.(3), takes into TSTF-425-A consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

1 CEOG STS San Onofre -- Draft B 3.8.1-26 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 129 of 437

Attachment 1, Volume 11, Rev. 0, Page 130 of 437 B 3.8.1 TSTF-425-A INSERT 27 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 4 appropriate choice of Frequency in the Surveillance Requirement.

Insert Page B 3.8.1-26 Attachment 1, Volume 11, Rev. 0, Page 130 of 437

Attachment 1, Volume 11, Rev. 0, Page 131 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) two This Surveillance is modified by three Notes. Note 1 states that 3 momentary transients due to changing bus loads do not invalidate this test. Similarly, momentary power factor transients above the power factor limit will not invalidate the test. The reason for Note 2 is that during operation with the reactor critical, performance of this Surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. This restriction from normally performing the Surveillance in MODE or is further amplified to allow the Surveillance to be performed 3 for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE or . Risk 11 insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR. Note 3 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of [0.9]. This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note 3 allows the Surveillance to be conducted at a power factor other than [0.9]. These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to INSERT 28 [0.9] results in voltages on the emergency busses that are too high. 3 Under these conditions, the power factor should be maintained as close as practicable to [0.9] while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor of [0.9]

may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such cases, the power factor shall be maintained as close practicable to [0.9]

without exceeding the DG excitation limits.

1 CEOG STS San Onofre -- Draft B 3.8.1-27 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 131 of 437

Attachment 1, Volume 11, Rev. 0, Page 132 of 437 B 3.8.1 3

INSERT 28 Note 2 requires the DG to operate within the power factor limit when synchronized with offsite power. However, this limit is not required to be met if the grid conditions do not permit, but the power factor must be maintained as close to the limit as practicable. The DG is tested under inductive load conditions that are as close to design conditions as possible. Testing is performed with DG kVAR output that offsite power system conditions permit during testing without exceeding equipment ratings (i.e., without creating an overvoltage condition on the ESF buses, over excitation condition in the generator, or overloading the DG main feeder). The kVAR loading requirement during the test is met, and the equipment ratings are not exceeded, when the DG kVAR output is increased such that:

a. kVAR is 3000 and 3200;

b. the excitation current is 3.8 A and 4.0 A for all EDGs except 3G003 and 5.1 A and 5.5 A for EDG 3G003;

c. the ESF bus voltage is 4530 V and 4550 V; or

d. DG feeder current is 730 A and 750 A.

This method of establishing kVAR loading ensures that, in addition to verifying the load carrying capability (kW) of the diesel engine, the reactive power (kVAR) and voltage regulation capability of the generator is verified to the extent practicable, consistent with the recommendations of Regulatory Guide 1.9 (Ref. 3) and Information Notice 91-13 (Ref. 12).

Insert Page B 3.8.1-27 Attachment 1, Volume 11, Rev. 0, Page 132 of 437

Attachment 1, Volume 11, Rev. 0, Page 133 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.15 This Surveillance demonstrates that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal 9.4 Surveillances, and achieve the required voltage and frequency within

[10] seconds. The [10] second time is derived from the requirements of 3 the accident analysis to respond to a design basis large break LOCA.

INSERT 29 The [18 month] Frequency is consistent with the recommendations of TSTF-425-A Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(5).

This SR is modified by two Notes. Note 1 ensures that the test is performed with the diesel sufficiently hot. The load band is provided to avoid routine overloading of the DG. Routine overloads may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY. The requirement that the diesel has operated for at least [2] hours at full load 2 conditions prior to performance of this Surveillance is based on manufacturer recommendations for achieving hot conditions. Momentary transients due to changing bus loads do not invalidate this test. Note 2 allows all DG starts to be preceded by an engine prelube period to minimize wear and tear on the diesel during testing.

9 3 SR 3.8.1.16 As required by Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(6), this 1 Surveillance ensures that the manual synchronization and automatic load transfer from the DG to the offsite source can be made and that the DG can be returned to ready to load status when offsite power is restored. It also ensures that the auto-start logic is reset to allow the DG to reload if a within steady state frequency ( 59.7 Hz and 61.2 Hz) and voltage ( 4161 subsequent loss of offsite power occurs. The DG is considered to be in V and 4576 V) limits ready to load status when the DG is at rated speed and voltage, the 1 output breaker is open and can receive and autoclose signal on bus 11 undervoltage, and the load sequence timers are reset.

INSERT 29 The Frequency of [18 months] is consistent with the recommendations of TSTF-425-A Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(6), and takes into consideration unit conditions required to perform the Surveillance.

1 CEOG STS San Onofre -- Draft B 3.8.1-28 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 133 of 437

Attachment 1, Volume 11, Rev. 0, Page 134 of 437 B 3.8.1 TSTF-425-A INSERT 29 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 4 appropriate choice of Frequency in the Surveillance Requirement.

Insert Page B 3.8.1-28 Attachment 1, Volume 11, Rev. 0, Page 134 of 437

Attachment 1, Volume 11, Rev. 0, Page 135 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service,

, 2, 3, perturb the electrical distribution system, and challenge safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 4 10 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a

, 2, 3, plant shutdown and startup to determine that plant safety is maintained or 4 enhanced when the Surveillance is performed in MODE 1 or 2. Risk 10 insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.

[ SR 3.8.1.17 safety Demonstration of the test mode override ensures that the DG availability injection under accident conditions will not be compromised as the result of testing and the DG will automatically reset to ready to load operation if a LOCA within the steady state frequency ( 59.7 Hz and actuation signal is received during operation in the test mode. Ready to 1 61.2 Hz) and voltage ( 4161 load operation is defined as the DG running at rated speed and voltage V and 4576 V) limits with the DG output breaker open. These provisions for automatic switchover are required by IEEE-308 (Ref. 13), paragraph 6.2.6(2).

The requirement to automatically energize the emergency loads with offsite power is essentially identical to that of SR 3.8.1.12. The intent in the requirement associated with SR 3.8.1.17.b is to show that the emergency loading was not affected by the DG operation in test mode. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the emergency loads to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

The [18 month] Frequency is consistent with the recommendations of INSERT 30 Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(8); takes into TSTF-425-A consideration unit conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.

1 CEOG STS San Onofre -- Draft B 3.8.1-29 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 135 of 437

Attachment 1, Volume 11, Rev. 0, Page 136 of 437 B 3.8.1 TSTF-425-A INSERT 30 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 4 appropriate choice of Frequency in the Surveillance Requirement.

Insert Page B 3.8.1-29 Attachment 1, Volume 11, Rev. 0, Page 136 of 437

Attachment 1, Volume 11, Rev. 0, Page 137 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, 12

, 2, 3, perturb the electrical distribution system, and challenge safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 4 10 is further amplified to allow portions of the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to

, 2, 3, determine that plant safety is maintained or enhanced when portions of 4 10 the Surveillance are performed in MODE 1 or 2. Risk insights or deterministic methods may be used for the assessment. Credit may be taken for unplanned events that satisfy this SR. ] 2 programmed time SR 3.8.1.18 interval load sequence Under accident [and loss of offsite power] conditions loads are 3

sequentially connected to the bus by the [automatic load sequencer]. The sequencing logic controls the permissive and starting signals to motor breakers to prevent overloading of the DGs due to high motor starting

+/- 10% or +/- 2.5 seconds start 3

(- 0.5, +2.5 seconds for currents. The [10]% load sequence time interval tolerance ensures that the 5 second load group) sufficient time exists for the DG to restore frequency and voltage prior to applying the next load and that safety analysis assumptions regarding 1 ESF equipment time delays are not violated. Reference 1 provides a summary of the automatic loading of ESF buses. 2 The Frequency of [18 months] is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(2); takes into TSTF-425-A INSERT 31 consideration unit conditions required to perform the Surveillance; and is intended to be consistent with expected fuel cycle lengths.

1 CEOG STS San Onofre -- Draft B 3.8.1-30 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 137 of 437

Attachment 1, Volume 11, Rev. 0, Page 138 of 437 B 3.8.1 TSTF-425-A INSERT 31 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 4 appropriate choice of Frequency in the Surveillance Requirement.

Insert Page B 3.8.1-30 Attachment 1, Volume 11, Rev. 0, Page 138 of 437

Attachment 1, Volume 11, Rev. 0, Page 139 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

This SR is modified by a Note. The reason for the Note is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and challenge safety systems.

This restriction from normally performing the Surveillance in MODE 1 or 2 3 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment.

Credit may be taken for unplanned events that satisfy this SR.

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

The above MODE restrictions may be deleted if it can be demonstrated to the staff, on a plant specific basis, that performing the SR with the reactor in any of the restricted MODES can satisfy the following criteria, as applicable: 4

a. Performance of the SR will not render any safety system or component inoperable,

b. Performance of the SR will not cause perturbations to any of the electrical distribution systems that could result in a challenge to steady state operation or to plant safety systems, and

c. Performance of the SR or failure of the SR will not cause or result in an AOO with attendant challenge to plant safety systems.

SR 3.8.1.19 In the event of a DBA coincident with a loss of offsite power, the DGs are required to supply the necessary power to ESF systems so that the fuel, RCS, and containment design limits are not exceeded.

1 CEOG STS San Onofre -- Draft B 3.8.1-31 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 139 of 437

Attachment 1, Volume 11, Rev. 0, Page 140 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued) actual or simulated This Surveillance demonstrates the DG operation, as discussed in the actual or simulated Bases for SR 3.8.1.11, during a loss of offsite power actuation test signal an 3 in conjunction with an ESF actuation signal. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the DG system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

TSTF-INSERT 32 The Frequency of [18 months] takes into consideration unit conditions 425-A required to perform the Surveillance and is intended to be consistent with an expected fuel cycle length of [18 months].

three This SR is modified by two Notes. The reason for Note 1 is to minimize 3 wear and tear on the DGs during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated and temperature maintained consistent with manufacturer recommendations for DGs. The reason for Note 2 is that performing the Surveillance would remove a required offsite circuit from service, perturb the electrical distribution system, and

, 2, 3, challenge safety systems. This restriction from normally performing the 4 Surveillance in MODE 1 or 2 is further amplified to allow portions of the 10 Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed partial Surveillance, a successful partial Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the partial Surveillance; as well as the operator procedures available to cope with these outcomes.

These shall be measured against the avoided risk of a plant shutdown

, 2, 3, and startup to determine that plant safety is maintained or enhanced 4 when portions of the Surveillance are performed in MODE 1 or 2. Risk 10 insights or deterministic methods may be used for the assessment.

Credit may be taken for unplanned events that satisfy this SR.

INSERT 33 3 1

CEOG STS San Onofre -- Draft B 3.8.1-32 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 140 of 437

Attachment 1, Volume 11, Rev. 0, Page 141 of 437 B 3.8.1 TSTF-425-A INSERT 32 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 4 appropriate choice of Frequency in the Surveillance Requirement.

3 INSERT 33 The Automatic Voltage Regulator (AVR) is discussed in Note 3. The AVR is an integral part of the DG; however, each DG has 2 AVRs that are 100% redundant to each other. Only one AVR is required to be OPERABLE and can be in service at any one time. To ensure OPERABILITY, each AVR must be in service during the performance of either SR 3.8.1.9, SR 3.8.1.10, or SR 3.8.1.19 each surveillance interval. Based on the design of the AVR, its intended function and the maintenance history, the above specified Surveillances will assure the AVRs are capable of performing their intended function.

Insert Page B 3.8.1-32 Attachment 1, Volume 11, Rev. 0, Page 141 of 437

Attachment 1, Volume 11, Rev. 0, Page 142 of 437 AC Sources - Operating B 3.8.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.20 This Surveillance demonstrates that the DG starting independence has not been compromised. Also, this Surveillance demonstrates that each engine can achieve proper speed within the specified time when the DGs are started simultaneously.

INSERT 34 The 10 year Frequency is consistent with the recommendations of TSTF-425-A Regulatory Guide 1.108 (Ref. 9).

This SR is modified by a Note. The reason for the Note is to minimize wear on the DG during testing. For the purpose of this testing, the DGs must be started from standby conditions, that is, with the engine coolant and oil continuously circulated, and temperature maintained consistent with manufacturer recommendations.

REFERENCES 1. 10 CFR 50, Appendix A, GDC 17.

2. FSAR, Chapter [8]. 1 U 3. Regulatory Guide 1.9, Rev. [3].

4. FSAR, Chapter [6]. 1

5. FSAR, Chapter [15]. 1

6. Regulatory Guide 1.93, Rev. [ ], [date]. 0

7. Generic Letter 84-15.

2

8. 10 CFR 50, Appendix A, GDC 18.

9. Regulatory Guide 1.108, Rev. [1], [August 1977].

10. Regulatory Guide 1.137, Rev. [ ], [date]. 1 Information Notice 91-13, "Inadequate Testing of

11. ANSI C84.1-1982. Emergency Diesel Generators (EDGs)" 09/16/91.

12. ASME Code for Operation and Maintenance of Nuclear Power 1 Plants.

13. IEEE Standard 308-[1978]. 1 TSTF-

14. CE NPSD-1186-A, Technical Justification for the Risk Informed Modification to Selected 422-A Required End States for CEOG PWRs, October, 2001

15. ANSI N195-1976.

1 CEOG STS San Onofre -- Draft B 3.8.1-33 Revision XXX Rev. 3.1, 12/01/05 Attachment 1, Volume 11, Rev. 0, Page 142 of 437

Attachment 1, Volume 11, Rev. 0, Page 143 of 437 B 3.8.1 TSTF-425-A INSERT 34 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 4 appropriate choice of Frequency in the Surveillance Requirement.

Insert Page B 3.8.1-33 Attachment 1, Volume 11, Rev. 0, Page 143 of 437

Attachment 1, Volume 11, Rev. 0, Page 144 of 437 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1 BASES, AC SOURCES-OPERATING

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. SR 3.8.1.2 was added to the ISTS SR 3.8.1.2 and SR 3.8.1.7 Bases to identify the SR 3.8.1.2 Note is being discussed.

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.

In addition, for SR 3.8.1.2 and SR 3.8.1.7, the phrase has been changed to

"...Frequencies for each..." since the two SRs will always have a different Frequency in the program.

7. ISTS 3.8.1 Required Actions A.2 and C.1 have been modified to state, "These redundant required features are those that are assumed to function to mitigate an accident, coincident with a loss of offsite power, in the safety analyses, such as the Emergency Core Cooling System and Auxiliary Feedwater System. These redundant required features do not include monitoring requirements, such as Post Accident Monitoring and Remote Shutdown." ISTS 3.8.1 Required Action B.2 has been modified to state, "Required Action B.2 is intended to provide assurance that a loss of offsite power , does not result in a complete loss of safety function of critical redundant required features." The purpose of Required Action A.2, B.2, and C.1 is to ensure that a complete loss of safety function does not occur should a loss of offsite power occur. Therefore, a "required feature" must have a safety function to provide in the event of an accident and mitigation of an accident, since safety functions fall into two categories: initial condition of an accident and mitigation of an accident. The Required Actions are, by definition, not consistent with initial conditions of the accident analyses. The initial conditions of the accident analyses are represented in the LCOs, and the Required Actions only apply when an LCO is not met. Therefore, Required Actions A.2, B.2, and C.1 are concerned with verifying that the safety function of accident mitigation can be performed. This is only a concern if the safety function is assumed to be performed during an accident coincident with a loss of offsite power. This is appropriate because without a loss of offsite power coincident with the accident, the existing electrical power configuration would persist and a full train of emergency power would be available. Lastly, systems which do not perform a San Onofre Unit 2 and 3 Page 1 of 2 Attachment 1, Volume 11, Rev. 0, Page 144 of 437

Attachment 1, Volume 11, Rev. 0, Page 145 of 437 JUSTIFICATION FOR DEVIATIONS ITS 3.8.1 BASES, AC SOURCES-OPERATING function assumed in the safety analysis, such as Power Accident Monitoring and Remote Shutdown, are not considered "required feature(s)" consistent with the existing statements in the Bases. These changes will eliminate confusion surrounding what is considered a "required feature."

8. The statement "It also allows for voltage drops to motors and other equipment down through the 120 V level where operating voltage is also usually specified as 80% of the name plate rating" has been changed to "This minimum voltage requirement also ensures that adequate voltage is provided to motors and other equipment down through the 120 V level." SONGS uses a detailed Electrical Transient Analyzer Program (ETAP) power system analysis and design software to verify that adequate voltage is provided to motors and other equipment for different alignments and loading conditions.

9. ISTS Bases for SR 3.8.1.3 contains the statement "Although no power factor requirements are established by this SR, the DG is normally operated at a power factor between [0.8 lagging] and [1.0]. The 0.8 value is the design rating of the machine, while [1.0] is an operational limit [to ensure circulating currents are minimized]." SONGS performs testing of DGs at a power factor that is representative of the actual inductive loading a DG would see under design accident conditions, while assuring it is compatible with the grid conditions.

Therefore, the statement was changed to indicate that the Surveillance is performed using inductive loading. This change is acceptable because it is consistent with the recommendations of Regulatory Guide 1.9.

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

11. Typographical/grammatical error corrected.

San Onofre Unit 2 and 3 Page 2 of 2 Attachment 1, Volume 11, Rev. 0, Page 145 of 437

Attachment 1, Volume 11, Rev. 0, Page 146 of 437 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 11, Rev. 0, Page 146 of 437

Attachment 1, Volume 11, Rev. 0, Page 147 of 437 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.1, AC SOURCES-SHUTDOWN There are no specific No Significant Hazards Considerations for this Specification.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 147 of 437

, Volume 11, Rev. 0, Page 148 of 437 ATTACHMENT 2 ITS 3.8.2, AC SOURCES-SHUTDOWN , Volume 11, Rev. 0, Page 148 of 437

, Volume 11, Rev. 0, Page 149 of 437 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 11, Rev. 0, Page 149 of 437

Attachment 1, Volume 11, Rev. 0, Page 150 of 437 ITS AC Sources Shutdown A01 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources Shutdown LCO 3.8.2 LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:

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

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

Applicability APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.

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

1. LCO 3.0.3 is not applicable. L01

2. LCO 3.0.4.b is not applicable for DGs.

ACTIONS ------------------------------- A02 CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One required offsite ------------NOTE-------------

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

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

OR A.2.1 Suspend CORE Immediately L02 ALTERATIONS.

AND (continued)

SAN ONOFRE--UNIT 2 3.8-17 Amendment No. 127 Attachment 1, Volume 11, Rev. 0, Page 150 of 437

Attachment 1, Volume 11, Rev. 0, Page 151 of 437 ITS AC Sources Shutdown A01 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 1

A. (continued) A.2.2 Suspend movement of Immediately L02 irradiated fuel assemblies.

AND 2

A.2.3 Suspend operations Immediately L02 involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND 3

A.2.4 Initiate action to Immediately L02 restore required offsite power circuit to OPERABLE status.

ACTION B B. One required DG B.1 Suspend CORE Immediately L02 inoperable. ALTERATIONS.

AND 1

B.2 Suspend movement of Immediately L02 irradiated fuel assemblies.

AND 2

B.3 Suspend operations Immediately L02 involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND 3

B.4 Initiate action to Immediately L02 restore required DG to OPERABLE status.

SAN ONOFRE--UNIT 2 3.8-18 Amendment No. 127,175 Attachment 1, Volume 11, Rev. 0, Page 151 of 437

Attachment 1, Volume 11, Rev. 0, Page 152 of 437 ITS A01 AC Sources Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 SR 3.8.2.1 -------------------NOTE-------------------

The following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.8 through SR 3.8.1.11, SR 3.8.1.13 through SR 3.8.1.16, SR 3.8.1.18, and SR 3.8.1.19.

9 and L03 For AC sources required to be OPERABLE, the In accordance SRs of Specification 3.8.1, "AC with applicable Sources Operating," except SR 3.8.1.17 and SRs SR 3.8.1.20, are applicable.

, SR 3.8.1.19, SR 3.8.1.8, SR 3.8.1.12, SAN ONOFRE--UNIT 2 3.8-19 Amendment No. 127 Attachment 1, Volume 11, Rev. 0, Page 152 of 437

Attachment 1, Volume 11, Rev. 0, Page 153 of 437 ITS AC Sources Shutdown A01 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources Shutdown LCO 3.8.2 LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:

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

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

Applicability APPLICABILITY: MODES 5 and 6, During movement of irradiated fuel assemblies.

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

1. LCO 3.0.3 is not applicable. L01

2. LCO 3.0.4.b is not applicable for DGs.

ACTIONS ------------------------------- A02 CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One required offsite ------------NOTE-------------

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

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

OR A.2.1 Suspend CORE Immediately L02 ALTERATIONS.

AND (continued)

SAN ONOFRE--UNIT 3 3.8-17 Amendment No. 116 Attachment 1, Volume 11, Rev. 0, Page 153 of 437

Attachment 1, Volume 11, Rev. 0, Page 154 of 437 ITS AC Sources Shutdown A01 3.8.2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 1

A. (continued) A.2.2 Suspend movement of Immediately L02 irradiated fuel assemblies.

AND 2

A.2.3 Suspend operations Immediately L02 involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND 3

A.2.4 Initiate action to Immediately L02 restore required offsite power circuit to OPERABLE status.

ACTION B B. One required DG B.1 Suspend CORE Immediately L02 inoperable. ALTERATIONS.

AND 1

B.2 Suspend movement of Immediately L02 irradiated fuel assemblies.

AND 2

B.3 Suspend operations Immediately L02 involving positive reactivity additions that could result in loss of required SDM or boron concentration.

AND 3

B.4 Initiate action to Immediately L02 restore required DG to OPERABLE status.

SAN ONOFRE--UNIT 3 3.8-18 Amendment No. 116,166 Attachment 1, Volume 11, Rev. 0, Page 154 of 437

Attachment 1, Volume 11, Rev. 0, Page 155 of 437 ITS A01 AC Sources Shutdown 3.8.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 SR 3.8.2.1 -------------------NOTE-------------------

The following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.8 through SR 3.8.1.11, SR 3.8.1.13 through SR 3.8.1.16, SR 3.8.1.18, and SR 3.8.1.19.

9 and L03 For AC sources required to be OPERABLE, the In accordance SRs of Specification 3.8.1, "AC with applicable Sources Operating," except SR 3.8.1.17 and SRs SR 3.8.1.20, are applicable.

, SR 3.8.1.19, SR 3.8.1.8, SR 3.8.1.12, SAN ONOFRE--UNIT 3 3.8-19 Amendment No. 116 Attachment 1, Volume 11, Rev. 0, Page 155 of 437

Attachment 1, Volume 11, Rev. 0, Page 156 of 437 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES-SHUTDOWN 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 3.8.2 ACTIONS include a Note (Note 2) that states LCO 3.0.4.b is not applicable to the DGs. CTS 3.8.2 does not include this Note. This changes the CTS by including the ACTIONS Note (Note 2) excluding the use of LCO 3.0.4.b for the DGs.

The purpose of the ITS 3.8.2 ACTIONS Note 2 is to prohibit entry into the Applicability of LCO 3.8.2 with an inoperable DG. Currently, CTS 3.8.2 and LCO 3.0.4 preclude entering MODE 5 when an AC electrical source is inoperable.

However, CTS LCO 3.0.4 has been modified as described in the Discussion of 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 restriction (LCO 3.0.4.b is not applicable to the DGs) is acceptable because there is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable DG, and therefore the provisions of LCO 3.0.4.b should not be applied in this circumstance. The change is acceptable because CTS 3.8.2 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.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None San Onofre Unit 2 and 3 Page 1 of 3 Attachment 1, Volume 11, Rev. 0, Page 156 of 437

Attachment 1, Volume 11, Rev. 0, Page 157 of 437 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES-SHUTDOWN LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) ITS 3.8.2 ACTIONS are modified by a Note (Note 1) that states LCO 3.0.3 is not applicable. CTS 3.8.2 ACTIONS do not contain this Note. This changes the CTS by adding a Note (Note 1) to the ACTIONS stating LCO 3.0.3 is not applicable.

The purpose of CTS 3.8.2 is to ensure sufficient AC sources are available to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents). The proposed change to CTS 3.8.2 adds a Note that modifies the ACTIONS by stating that LCO 3.0.3 is not applicable. This change is acceptable because when moving irradiated fuel assemblies while in MODES 5 and 6, LCO 3.0.3 would not specify any action. If moving irradiated fuel assemblies while in MODES 1, 2, 3, or 4, the fuel movement is independent of reactor operations. This clarification is necessary because defaulting to LCO 3.0.3 (during irradiated fuel assembly movement in MODE 1, 2, 3, or 4) would require the reactor to be shutdown unnecessarily. This change is designated as less restrictive because a Note which relaxes the Required Actions is included in the ITS that is not currently included in the CTS.

L02 (Category 4 - Relaxation of Required Action) CTS 3.8.2 ACTIONS A and B specify compensatory actions when one required offsite circuit or one required DG, respectively, are inoperable. One of the compensatory actions is to suspend CORE ALTERATIONS. Under similar conditions, ITS 3.8.2 ACTIONS do not require suspension of CORE ALTERATIONS. This changes the CTS by deleting the requirement to suspend CORE ALTERATIONS when one required offsite circuit or one required DG is inoperable. Additionally, subsequent Required Actions have been renumbered.

The purpose of CTS LCO 3.8.2 is to ensure sufficient AC sources are available to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents). When the required offsite circuit or DG is not OPERABLE, CTS 3.8.2 ACTIONS suspend CORE ALTERATIONS to preclude an event that could result in not meeting the SHUTDOWN MARGIN limit. CORE ALTERATIONS is defined in CTS 1.1, in part, as "the movement or manipulation of any fuel, reactivity control components, sources, or other componentsaffecting reactivity within the reactor vessel with the vessel head removed and fuel in the vessel." There are two evolutions encompassed under the term CORE ALTERATIONS that could affect the SHUTDOWN MARGIN: addition of fuel to the reactor vessel and withdrawal of control rods. However, ITS 3.8.2 Required Actions A.2.1 and B.1 require immediate suspension of movement of irradiated fuel assemblies and ITS Required Actions A.2.2 and B.2 require suspension of operations involving positive reactivity additions that could result in loss of required SDM or boron concentration. This would include both the addition of fuel to the reactor vessel and the withdrawal of control rods. Furthermore, another accident considered in MODE 6 that could affect SHUTDOWN MARGIN is the boron dilution event. A boron dilution accident is initiated by a dilution source which results in the boron concentration dropping below that required to maintain the SHUTDOWN MARGIN. A boron dilution accident is mitigated by stopping the dilution.

Suspension of CORE ALTERATIONS has no affect on the mitigation of a boron San Onofre Unit 2 and 3 Page 2 of 3 Attachment 1, Volume 11, Rev. 0, Page 157 of 437

Attachment 1, Volume 11, Rev. 0, Page 158 of 437 DISCUSSION OF CHANGES ITS 3.8.2, AC SOURCES-SHUTDOWN dilution accident. In summary, with the exception of suspending movement of fuel assemblies, there are no DBAs or transients that are initiated by, or mitigation affected by, suspension of CORE ALTERATIONS. Therefore, if all Required Actions that require suspension of CORE ALTERATIONS also require suspension of movement of fuel, suspension of CORE ALTERATIONS provides no safety benefit. Thus, the deletion of the requirement to suspend CORE ALTERATIONS is acceptable. This change is designated as less restrictive because less stringent Required Actions are being applied to the ITS than were applied in the CTS.

L03 (Category 5 - Deletion of Surveillance Requirement) CTS SR 3.8.2.1 states that for the AC sources required to be OPERABLE, the SRs of Specification 3.8.1, "AC Sources-Operating," except SR 3.8.1.17 and SR 3.8.1.20, are applicable.

CTS SR 3.8.2.1 is modified by a Note which states the following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.8 through SR 3.8.1.11, SR 3.8.1.13 through SR 3.8.1.16, SR 3.8.1.18, and SR 3.8.1.19. ITS SR 3.8.2.1 states that for the AC sources required to be OPERABLE, the SRs of Specification 3.8.1, AC Sources-Operating, except SR 3.8.1.8, SR 3.8.1.12, SR 3.8.1.17, SR 3.8.1.19, and SR 3.8.1.20, are applicable. ITS SR 3.8.2.1 is modified by a Note which states the following SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.1.11, SR 3.8.1.13 through SR 3.8.1.16, and SR 3.8.1.18. This changes the CTS by adding SR 3.8.1.8, SR 3.8.1.12, and SR 3.8.1.19 to the SRs that are exempted from being performed to satisfy SR 3.8.2.1.

The purpose of CTS SR 3.8.2.1 is to require performance of SRs from CTS 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in MODES 5 and 6, and during movement of fuel assemblies. The proposed change to CTS SR 3.8.2.1 adds three additional SRs (SR 3.8.1.8, SR 3.8.1.12, and SR 3.8.1.19) that are not applicable in MODES 5 and 6, and during movement of fuel assemblies. This change is acceptable because SR 3.8.1.8 is not required to be met since only one offsite circuit is required to be OPERABLE and SRs 3.8.1.12 and 3.8.1.19 are not required to be met because the ESF actuation signal is not required to be OPERABLE in MODES 5 and 6 or during movement of fuel assemblies, as shown in CTS 3.3.5. SR 3.8.1.8 requires verifying the capability of automatic and manual transfer of AC power sources from the normal offsite circuit to each alternate required offsite circuit. With only one offsite circuit required to be OPERABLE, SR 3.8.1.8 is not necessary (since there is no technical reason to demonstrate transfer capability). SR 3.8.1.12 and SR 3.8.1.19 both require ESF signals for the SR to be performed. The applicable ESF signals are not required to be OPERABLE in MODES 5 and 6 or during movement of fuel assemblies; therefore, the SRs are not required to be performed. This change is designated as less restrictive, because SRs that were "required to be performed" or "required to be met" for the CTS will not be required for the ITS.

San Onofre Unit 2 and 3 Page 3 of 3 Attachment 1, Volume 11, Rev. 0, Page 158 of 437

Attachment 1, Volume 11, Rev. 0, Page 159 of 437 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 159 of 437

Attachment 1, Volume 11, Rev. 0, Page 160 of 437 U2/U3 CTS AC Sources - Shutdown 3.8.2 3.8 ELECTRICAL POWER SYSTEMS 3.8.2 AC Sources - Shutdown LCO 3.8.2 LCO 3.8.2 The following AC electrical power sources shall be OPERABLE:

a. One qualified circuit between the offsite transmission network and the onsite Class 1E AC electrical power distribution subsystem(s) 4 required by LCO 3.8.10, "Distribution Systems Shutdown" and train(s)

b. One diesel generator (DG) capable of supplying one train of the onsite Class 1E AC electrical power distribution subsystem(s) 4 required by LCO 3.8.10.

train(s)

Applicability APPLICABILITY: MODES 5 and 6, During movement of [recently] irradiated fuel assemblies. 2 ACTIONS S 1.

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

DOC L01 LCO 3.0.3 is not applicable. 3 DOC A02 2. LCO 3.0.4.b is not applicable for DGs.

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

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

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

OR 1

CEOG STS San Onofre -- Draft 3.8.2-1 Amendment XXX Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 160 of 437

Attachment 1, Volume 11, Rev. 0, Page 161 of 437 U2/U3 CTS AC Sources - Shutdown 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME TSTF-A.2.1 Suspend CORE Immediately 471-A ALTERATIONS.

AND TSTF-A.2.2 Suspend movement of Immediately 471-A

[recently] irradiated fuel 2 1

assemblies.

AND A.2.3 Suspend operations Immediately TSTF-471-A involving positive reactivity 2

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

AND TSTF-A.2.4 Initiate action to restore Immediately 471-A required offsite power 3

circuit to OPERABLE status.

ACTION B B. One required DG B.1 Suspend CORE Immediately TSTF-inoperable. ALTERATIONS. 471-A AND TSTF-B.2 Suspend movement of Immediately 471-A 1 [recently] irradiated fuel 2 assemblies.

AND TSTF-B.3 Suspend operations Immediately 471-A involving positive reactivity 2

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

AND 1

CEOG STS San Onofre -- Draft 3.8.2-2 Amendment XXX Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 161 of 437

Attachment 1, Volume 11, Rev. 0, Page 162 of 437 U2/U3 CTS AC Sources - Shutdown 3.8.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME TSTF-B.4 Initiate action to restore Immediately 471-A required DG to OPERABLE 3

status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.2.1 SR 3.8.2.1 ------------------------------NOTE------------------------------

The following SRs are not required to be performed:

SR 3.8.1.3, SR 3.8.1.9 through SR 3.8.1.11, SR 3.8.1.13 through SR 3.8.1.16, and 2

[SR 3.8.1.18].

For AC sources required to be OPERABLE, the SRs In accordance of Specification 3.8.1, "AC Sources - Operating," with applicable except SR 3.8.1.8, SR 3.8.1.12, SR 3.8.1.17, SRs SR 3.8.1.19, and SR 3.8.1.20, are applicable.

1 CEOG STS San Onofre -- Draft 3.8.2-3 Amendment XXX Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 162 of 437

Attachment 1, Volume 11, Rev. 0, Page 163 of 437 JUSTIFICATION FOR DEVIATIONS ITS 3.8.2, AC SOURCES-SHUTDOWN

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. A second Note has been added to the ITS 3.8.2 ACTIONS which states that LCO 3.0.4.b is not applicable for DGs. This type of Note was added throughout NUREG 1432 when TSTF-359 modified ISTS LCO 3.0.4 and the TSTF wanted to preclude the use of LCO 3.0.4.b in the changing MODES in an inoperable component or subsystem. The model safety evaluation for TSTF-359 states that LCO 3.0.4.b cannot be used for the DGs in any MODE. However, the Note was not added to NUREG-1432 for ISTS 3.8.2. Without the addition of the Note, SCE believes that certain conditions could arise when the DGs become inoperable in MODE 6, and the Note would not preclude changing MODES to MODE 5. Thus the Note would not preclude the use of LCO 3.0.4.b to perform this MODE change. This would have to be precluded administratively. In order to preclude a misinterpretation, SCE is adding the Note which states that LCO 3.0.4.b is not applicable for the diesel generators.

4. Changes made to be consistent with changes made to LCO 3.8.10.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 163 of 437

Attachment 1, Volume 11, Rev. 0, Page 164 of 437 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 11, Rev. 0, Page 164 of 437

Attachment 1, Volume 11, Rev. 0, Page 165 of 437 AC Sources - Shutdown B 3.8.2 B 3.8 ELECTRICAL POWER SYSTEMS B 3.8.2 AC Sources - Shutdown BASES BACKGROUND A description of the AC sources is provided in the Bases for LCO 3.8.1, "AC Sources - Operating."

APPLICABLE The OPERABILITY of the minimum AC sources during MODES 5 and 6 SAFETY and during movement of [recently] irradiated fuel assemblies ensures 2 ANALYSES that:

a. The unit can be maintained in the shutdown or refueling condition for extended periods,

b. Sufficient instrumentation and control capability is available for monitoring and maintaining the unit status, and

c. Adequate AC electrical power is provided to mitigate events postulated during shutdown, such as a fuel handling accident

[involving handling recently irradiated fuel. Due to radioactive decay, AC electrical power is only required to mitigate fuel handling 2 accidents involving handling recently irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)].

In general, when the unit is shut down, the Technical Specifications requirements ensure that the unit has the capability to mitigate the consequences of postulated accidents. However, assuming a single failure and concurrent loss of all offsite or all onsite power is not required.

The rationale for this is based on the fact that many Design Basis Accidents (DBAs) that are analyzed in MODES 1, 2, 3, and 4 have no specific analyses in MODES 5 and 6. Worst case bounding events are deemed not credible in MODES 5 and 6 because the energy contained within the reactor pressure boundary, reactor coolant temperature and pressure, and the corresponding stresses result in the probabilities of occurrence being significantly reduced or eliminated, and in minimal consequences. These deviations from DBA analysis assumptions and design requirements during shutdown conditions are allowed by the LCO for required systems.

1 CEOG STS San Onofre -- Draft B 3.8.2-1 Revision XXX Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 165 of 437

Attachment 1, Volume 11, Rev. 0, Page 166 of 437 AC Sources - Shutdown B 3.8.2 BASES APPLICABLE SAFETY ANALYSES (continued)

During MODES 1, 2, 3, and 4, various deviations from the analysis assumptions and design requirements are allowed within the Required Actions. This allowance is in recognition that certain testing and maintenance activities must be conducted provided an acceptable level of risk is not exceeded. During MODES 5 and 6, performance of a significant number of required testing and maintenance activities is also required. In MODES 5 and 6, the activities are generally planned and administratively controlled. Relaxations from MODE 1, 2, 3, and 4 LCO requirements are acceptable during shutdown modes based on:

a. The fact that time in an outage is limited. This is a risk prudent goal as well as a utility economic consideration.

b. Requiring appropriate compensatory measures for certain conditions.

These may include administrative controls, reliance on systems that do not necessarily meet typical design requirements applied to systems credited in operating MODE analyses, or both.

c. Prudent utility consideration of the risk associated with multiple activities that could affect multiple systems.

d. Maintaining, to the extent practical, the ability to perform required functions (even if not meeting MODE 1, 2, 3, and 4 OPERABILITY requirements) with systems assumed to function during an event.

In the event of an accident during shutdown, this LCO ensures the capability to support systems necessary to avoid immediate difficulty, assuming either a loss of all offsite power or a loss of all onsite diesel generator (DG) power.

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

LCO train(s)

One offsite circuit capable of supplying the onsite Class 1E power 3

distribution subsystem(s) of LCO 3.8.10, "Distribution Systems -

Shutdown," ensures that all required loads are powered from offsite power. An OPERABLE DG, associated with a distribution system train required to be OPERABLE by LCO 3.8.10, ensures a diverse power source is available to provide electrical power support, assuming a loss of the offsite circuit. Together, OPERABILITY of the required offsite circuit and DG ensures the availability of sufficient AC sources to operate the unit in a safe manner and to mitigate the consequences of postulated events during shutdown (e.g., fuel handling accidents [involving handling recently irradiated fuel]). 2 1

CEOG STS San Onofre -- Draft B 3.8.2-2 Revision XXX Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 166 of 437

Attachment 1, Volume 11, Rev. 0, Page 167 of 437 AC Sources - Shutdown B 3.8.2 BASES LCO (continued)

The qualified offsite circuit must be capable of maintaining rated frequency and voltage, and accepting required loads during an accident, while connected to the Engineered Safety Feature (ESF) bus(es).

Qualified offsite circuits are those that are described in the FSAR and are 1 part of the licensing basis for the unit. U

[ Offsite circuit #1 consists of Safeguards Transformer B, which is supplied from Switchyard Bus B, and is fed through breaker 52-3 powering the 2

INSERT 1 ESF transformer XNBO1, which, in turn, powers the #1 ESF bus through its normal feeder breaker. The second offsite circuit consists of the Startup Transformer, which is normally fed from the Switchyard Bus A, and is fed through breaker PA 0201 powering the ESF transformer, which, in turn, powers the #2 ESF bus through its normal feeder breaker. ]

The DG must be capable of starting, accelerating to rated speed and voltage, connecting to its respective ESF bus on detection of bus undervoltage, and accepting required loads. This sequence must be 2

accomplished within [10] seconds. The DG must be capable of accepting required loads within the assumed loading sequence intervals, and must continue to operate until offsite power can be restored to the ESF buses.

These capabilities are required to be met from a variety of initial conditions such as DG in standby with the engine hot and DG in standby at ambient conditions.

Proper sequencing of loads, including tripping of nonessential loads, is a required function for DG OPERABILITY.

[In addition, proper sequencer operation is an integral part of offsite circuit 2 INSERT 2 OPERABILITY since its inoperability impacts on the ability to start and maintain energized loads required OPERABLE by LCO 3.8.10. ]

It is acceptable for trains to be cross tied during shutdown conditions, allowing a single offsite power circuit to supply all required trains.

APPLICABILITY The AC sources required to be OPERABLE in MODES 5 and 6 and 3

during movement of [recently] irradiated fuel assemblies provide assurance that:

a. Systems to provide adequate coolant inventory makeup are available for the irradiated fuel assemblies, 1

CEOG STS San Onofre -- Draft B 3.8.2-3 Revision XXX Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 167 of 437

Attachment 1, Volume 11, Rev. 0, Page 168 of 437 B 3.8.2 2

INSERT 1 One source of offsite power (offsite circuit #1) for each unit is normally provided through Reserve Auxiliary Transformers XR1 and XR2 for the specific unit. XR1 feeds one 4.16 kV ESF bus (Train A) A04 and XR2 feeds the other 4.16 kV bus (Train B) A06 of the onsite Class 1E AC distribution system for each unit. The second source of offsite power (offsite circuit #2) is provided by the other units Reserve Auxiliary Transformers XR1 and XR2 through the train oriented 4.16 kV ESF bus crossties between the two units. In addition an alternate offsite source of power for each unit would be, with the units main generator isophase bus links removed, each units Main Transformer and the Unit Auxiliary Transformer XU1.

2 INSERT 2 Load sequencing is accomplished through the programmed time load sequence interval utilizing individual timing relays for each load in lieu of a single automatic load sequencer.

Insert Page B 3.8.2-3 Attachment 1, Volume 11, Rev. 0, Page 168 of 437

Attachment 1, Volume 11, Rev. 0, Page 169 of 437 AC Sources - Shutdown B 3.8.2 BASES APPLICABILITY (continued)

b. Systems needed to mitigate a fuel handling accident [involving 2

handling [recently] irradiated fuel (i.e., fuel that has occupied part of a critical reactor core within the previous [X] days)] are available,

c. Systems necessary to mitigate the effects of events that can lead to core damage during shutdown are available, and

d. Instrumentation and control capability is available for monitoring and maintaining the unit in a cold shutdown condition or refueling condition.

The AC power requirements for MODES 1, 2, 3, and 4 are covered in LCO 3.8.1.

ACTIONS LCO 3.0.3 is not applicable while in MODE 5 or 6. However, since The ACTIONS are irradiated fuel assembly movement can occur in MODE 1, 2, 3, or 4, the 1 modified by two Notes. ACTIONS have been modified by a Note stating that LCO 3.0.3 is not 3 Note 2 prohibits the applicable. If moving irradiated fuel assemblies while in MODE 5 or 6, application of LCO 3.0.4.b LCO 3.0.3 would not specify any action. If moving irradiated fuel to an inoperable DG. There assemblies while in MODE 1, 2, 3, or 4, the fuel movement is is an increased risk associated with entering a independent of reactor operations. Entering LCO 3.0.3, while in MODE 1, MODE or other specified 2, 3, or 4 would require the unit to be shutdown unnecessarily.

condition in the Applicability with an inoperable DG and 3 the provisions of LCO 3.0.4.b, which allow entry A.1 into a MODE or other specified condition in the Applicability with the LCO An offsite circuit would be considered inoperable if it were not available to not met after performance one required ESF train. Although two trains may be required by of a risk assessment addressing inoperable LCO 3.8.10, the remaining train with offsite power available may be systems and components, capable of supporting sufficient required features to allow continuation of TSTF-should not be applied in this 2 CORE ALTERATIONS and [recently] irradiated fuel movement. By the 471-A circumstance.

allowance of the option to declare required features inoperable, with no offsite power available, appropriate restrictions will be implemented in accordance with the affected required features LCO's ACTIONS.

3 TSTF-A.2.1, A.2.2, A.2.3, A.2.4, B.1, B.2, B.3, and B.4 471-A With the offsite circuit not available to all required trains, the option would still exist to declare all required features inoperable. Since this option may involve undesired administrative efforts, the allowance for sufficiently conservative actions is made. With the required DG inoperable, the 1

CEOG STS San Onofre -- Draft B 3.8.2-4 Revision XXX Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 169 of 437

Attachment 1, Volume 11, Rev. 0, Page 170 of 437 AC Sources - Shutdown B 3.8.2 BASES ACTIONS (continued) minimum required diversity of AC power sources is not available. It is, TSTF-therefore, required to suspend CORE ALTERATIONS, movement of 471-A

[recently] irradiated fuel assemblies, and operations involving positive 3 reactivity additions that could result in loss of required SDM (MODE 5) or boron concentration (MODE 6). Suspending positive reactivity additions that could result in failure to meet the minimum SDM or boron concentration limit is required to assure continued safe operation.

Introduction of coolant inventory must be from sources that have a boron concentration greater than that what would be required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

Suspension of these activities does not preclude completion of actions to establish a safe conservative condition. These actions minimize the probability or the occurrence of postulated events. It is further required to immediately initiate action to restore the required AC sources and to continue this action until restoration is accomplished in order to provide the necessary AC power to the unit safety systems.

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required AC electrical power sources should be completed as quickly as possible in order to minimize the time during which the unit safety systems may be without sufficient power.

Pursuant to LCO 3.0.6, the Distribution System's ACTIONS are not entered even if all AC sources to it are inoperable, resulting in de-energization. Therefore, the Required Actions of Condition A are modified by a Note to indicate that when Condition A is entered with no AC power to any required ESF bus, the ACTIONS for LCO 3.8.10 must be immediately entered. This Note allows Condition A to provide requirements for the loss of the offsite circuit, whether or not a train is de-energized. LCO 3.8.10 provides the appropriate restrictions for the situation involving a de-energized train.

1 CEOG STS San Onofre -- Draft B 3.8.2-5 Revision XXX Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 170 of 437

Attachment 1, Volume 11, Rev. 0, Page 171 of 437 AC Sources - Shutdown B 3.8.2 BASES SURVEILLANCE SR 3.8.2.1 REQUIREMENTS SR 3.8.2.1 requires the SRs from LCO 3.8.1 that are necessary for ensuring the OPERABILITY of the AC sources in other than MODES 1, 2, 3, and 4. SR 3.8.1.8 is not required to be met since only one offsite circuit is required to be OPERABLE. SR 3.8.1.12 and SR 3.8.1.19 are not required to be met because the ESF actuation signal is not required to be OPERABLE. SR 3.8.1.17 is not required to be met because the required OPERABLE DG(s) is not required to undergo periods of being 4 synchronized to the offsite circuit. SR 3.8.1.20 is excepted because starting independence is not required with DG(s) that are not required to be OPERABLE.

This SR is modified by a Note. The reason for the Note is to preclude requiring the OPERABLE DG(s) from being paralleled with the offsite 4 power network or otherwise rendered inoperable during performance of SRs, and to preclude deenergizing a required 4160 V ESF bus or disconnecting a required offsite circuit during performance of SRs. With limited AC Sources available, a single event could compromise both the required circuit and the DG. It is the intent that these SRs must still be capable of being met, but actual performance is not required during periods when the DG and offsite circuit is required to be OPERABLE.

Refer to the corresponding Bases for LCO 3.8.1 for a discussion of each SR.

REFERENCES None.

1 CEOG STS San Onofre -- Draft B 3.8.2-6 Revision XXX Rev. 3.0, 03/31/04 Attachment 1, Volume 11, Rev. 0, Page 171 of 437

Attachment 1, Volume 11, Rev. 0, Page 172 of 437 JUSTIFICATION FOR DEVIATIONS ITS 3.8.2 BASES, AC SOURCES-SHUTDOWN

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 made to be consistent with changes made to the Specification.

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

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 172 of 437

Attachment 1, Volume 11, Rev. 0, Page 173 of 437 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 11, Rev. 0, Page 173 of 437

Attachment 1, Volume 11, Rev. 0, Page 174 of 437 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.8.2, AC SOURCES-SHUTDOWN There are no specific No Significant Hazards Considerations for this Specification.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 11, Rev. 0, Page 174 of 437

Attachment 1, Volume 11, Rev. 0, Page 175 of 437 ATTACHMENT 3 ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR Attachment 1, Volume 11, Rev. 0, Page 175 of 437

, Volume 11, Rev. 0, Page 176 of 437 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 11, Rev. 0, Page 176 of 437

Attachment 1, Volume 11, Rev. 0, Page 177 of 437 Diesel Fuel Oil, Lube Oil, and Starting Air ITS A01 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air LCO 3.8.3 LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required diesel generator (DG).

Applicability APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS

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

ACTIONS Separate Condition entry is allowed for each DG.

Note CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One or more DGs with A.1 Restore fuel oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months fuel volume < 48,400 level to within gallons and > 41,800 limits. LA01 greater than a gallons in storage less than a 7 6 day supply tank during MODE 1,2,3 day supply or 4. M01 A02 ACTION B B. One or more DGs B.1 Restore lube oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months with lube oil inventory to within inventory < TS min limits.

and $ TS inop. LA01 less than a 7 day supply and greater than a 6 day supply ACTION A C. One required DG with C.1 Restore fuel oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months fuel volume in the level to within A02 storage tank < 43,600 limits.

gallons and > 37,400 gallons during MODE 5 or 6.

ACTION C D. One or more DGs with D.1 Restore fuel oil 7 days stored fuel oil total total particulates to particulates not within limits.

within limits.

(continued)

SAN ONOFRE--UNIT 2 3.8-20 Amendment No. 211 Attachment 1, Volume 11, Rev. 0, Page 177 of 437

Attachment 1, Volume 11, Rev. 0, Page 178 of 437 Diesel Fuel Oil, Lube Oil, and Starting Air ITS A01 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION D E. One or more DGs with E.1 Restore stored fuel 30 days new fuel oil oil properties to properties not within within limits.

limits.

ACTION E F. One or more DGs with F.1 Restore starting air 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months starting air receiver receiver pressure to pressure < 175 psig $ 175 psig.

and $ 136 psig.

ACTION F G. Required Action and G.1 Declare associated DG Immediately associated Completion inoperable.

Time of Condition A, B, C, D, E or F not met.

OR One or more DGs with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than Condition A, B, C, D, E, or F.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 SR 3.8.3.1 Verify each fuel oil storage tank contains 31 days LA01 LA02

$ 48,400 gallons in MODE 1,2,3 or 4 and a 7 day supply of fuel

$ 43,600 gallons in MODE 5 or 6.

M01 (continued)

In accordance with the Surveillance Frequency Control Program SAN ONOFRE--UNIT 2 3.8-21 Amendment No. 211 Attachment 1, Volume 11, Rev. 0, Page 178 of 437

Attachment 1, Volume 11, Rev. 0, Page 179 of 437 A01 Diesel Fuel Oil, Lube Oil, and Starting Air ITS 3.8.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.3.2 SR 3.8.3.2 Verify lubricating oil inventory is $ TS 31 days LA02 LA01 min limit.

a 7 day supply In accordance with the Surveillance Frequency Control Program SR 3.8.3.3 SR 3.8.3.3 Verify fuel oil properties of new and In accordance stored fuel oil are tested in accordance with the Diesel with, and maintained within the limits of, Fuel Oil the Diesel Fuel Oil Testing Program. Testing Program SR 3.8.3.4 SR 3.8.3.4 Verify each DG air start receiver pressure 31 days LA02 is $ 175 psig.

In accordance with the Surveillance Frequency Control Program SR 3.8.3.5 SR 3.8.3.5 Check for and remove accumulated water from 31 days each fuel oil storage tank. LA02 SR 3.8.3.6 For each fuel oil storage tank: 10 years

a. Drain the fuel oil; LA03

b. Remove the sediment; and

c. Clean the tank.

SAN ONOFRE--UNIT 2 3.8-22 Amendment No. 127 Attachment 1, Volume 11, Rev. 0, Page 179 of 437

Attachment 1, Volume 11, Rev. 0, Page 180 of 437 Diesel Fuel Oil, Lube Oil, and Starting Air ITS A01 3.8.3 3.8 ELECTRICAL POWER SYSTEMS 3.8.3 Diesel Fuel Oil, Lube Oil, and Starting Air LCO 3.8.3 LCO 3.8.3 The stored diesel fuel oil, lube oil, and starting air subsystem shall be within limits for each required diesel generator (DG).

Applicability APPLICABILITY: When associated DG is required to be OPERABLE.

ACTIONS

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

ACTIONS Separate Condition entry is allowed for each DG.

Note CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One or more DGs with A.1 Restore fuel oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months fuel volume < 48,400 level to within gallons and > 41,800 limits. LA01 greater than a gallons in storage less than a 7 6 day supply tank during MODE 1,2,3 day supply M01 or 4. A02 ACTION B B. One or more DGs with B.1 Restore lube oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months lube oil inventory inventory to within

< TS min and $ TS limits.

inop. LA01 less than a 7 day supply and greater than a 6 day supply ACTION A C. One required DG with C.1 Restore fuel oil 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months fuel volume in the level to within A02 storage tank < 43,600 limits.

gallons and > 37,400 gallons during MODE 5 or 6.

ACTION C D. One or more DGs with D.1 Restore fuel oil 7 days stored fuel oil total total particulates to particulates not within limits.

within limits.

(continued)

SAN ONOFRE--UNIT 3 3.8-20 Amendment No. 203 Attachment 1, Volume 11, Rev. 0, Page 180 of 437

Attachment 1, Volume 11, Rev. 0, Page 181 of 437 Diesel Fuel Oil, Lube Oil, and Starting Air ITS A01 3.8.3 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION D E. One or more DGs with E.1 Restore stored fuel 30 days new fuel oil oil properties to properties not within within limits.

limits.

ACTION E F. One or more DGs with F.1 Restore starting air 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months starting air receiver receiver pressure to pressure < 175 psig $ 175 psig.

and $ 136 psig.

ACTION F G. Required Action and G.1 Declare associated DG Immediately associated Completion inoperable.

Time of Condition A, B, C, D, E or F not met.

OR One or more DGs with diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than Condition A, B, C, D, E, or F.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 SR 3.8.3.1 Verify each fuel oil storage tank contains 31 days LA01 LA02

$ 48,400 gallons in MODE 1,2,3 or 4 and a 7 day supply of fuel

$ 43,600 gallons in MODE 5 or 6.

M01 (continued)

In accordance with the Surveillance Frequency Control Program SAN ONOFRE--UNIT 3 3.8-21 Amendment No. 203 Attachment 1, Volume 11, Rev. 0, Page 181 of 437

Attachment 1, Volume 11, Rev. 0, Page 182 of 437 A01 Diesel Fuel Oil, Lube Oil, and Starting Air ITS 3.8.3 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.8.3.2 SR 3.8.3.2 Verify lubricating oil inventory is $ TS 31 days LA01 LA02 min limit.

a 7 day supply In accordance with the Surveillance Frequency Control Program SR 3.8.3.3 SR 3.8.3.3 Verify fuel oil properties of new and In accordance stored fuel oil are tested in accordance with the Diesel with, and maintained within the limits of, Fuel Oil the Diesel Fuel Oil Testing Program. Testing Program SR 3.8.3.4 SR 3.8.3.4 Verify each DG air start receiver pressure 31 days LA02 is $ 175 psig.

In accordance with the Surveillance Frequency Control Program SR 3.8.3.5 SR 3.8.3.5 Check for and remove accumulated water from 31 days each fuel oil storage tank. LA02 SR 3.8.3.6 For each fuel oil storage tank: 10 years

a. Drain the fuel oil; LA03

b. Remove the sediment; and

c. Clean the tank.

SAN ONOFRE--UNIT 3 3.8-22 Amendment No. 116 Attachment 1, Volume 11, Rev. 0, Page 182 of 437

Attachment 1, Volume 11, Rev. 0, Page 183 of 437 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR 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 3.8.3 ACTION A provides the actions when the DG fuel oil storage tank requirements are not met in MODES 1, 2, 3, and 4 and CTS 3.8.3 ACTION C provides the actions when the DG fuel oil storage tank requirements are not met in MODES 5 and 6. ITS 3.8.3 ACTION A provides the actions when the DG fuel oil storage tank requirements are not met at all times when the DGs are required to be OPERABLE. This changes the CTS requirements by combining the fuel oil storage tank actions into a single ACTION. The change related to moving irradiated fuel assemblies is discussed in DOC M01.

The purpose of CTS 3.8.3 ACTIONS A and C is to ensure appropriate action is taken when the DG fuel oil storage tank volume is < a 7 day supply and > a 6 day supply. The proposed change combines the two ACTIONS without affecting the individual actions. This change is designated as administrative because it does not technically alter the Specification.

MORE RESTRICTIVE CHANGES M01 CTS 3.8.3 requires the stored diesel fuel oil, lube oil, and starting air subsystem to be within limits for each required diesel generator when the associated DG is required to be OPERABLE. Required Actions are provided when the DG fuel oil storage tank is not within limits; however, ACTIONS are only provided for when in MODES 1 through 6. There are no CTS ACTIONS when not in MODES 1, 2, 3, 4, 5, or 6 and irradiated fuel assembly movement is occurring, which is also covered by the Applicability of CTS 3.8.2. Also CTS SR 3.8.3.1 only requires volume in the fuel oil storage tank to be verified in MODES 1 through 6; not during movement of irradiated fuel assemblies. ITS 3.8.3 Condition A contains a Condition when the diesel fuel oil storage tank is not within limits, and covers all MODES and other specified conditions in the Applicability of ITS 3.8.3. In addition, ITS SR 3.8.3.1 also ensures that the volume of fuel oil in the storage tanks is checked in all the MODES and other specified conditions when the DGs are required to be OPERABLE (i.e., it covers MODES 1 through 6 and when moving irradiated fuel assemblies). This changes the CTS by adding an ACTION and SR for the fuel oil storage tank volume when not in MODES 1, 2, 3, 4, 5 or 6 and irradiated fuel assembly movement is occurring.

The purpose of the diesel fuel oil storage tank ACTIONS and SR is to ensure a 7 day supply of fuel oil is available for the DG at all times when the DG is required San Onofre Unit 2 and 3 Page 1 of 6 Attachment 1, Volume 11, Rev. 0, Page 183 of 437

Attachment 1, Volume 11, Rev. 0, Page 184 of 437 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR to be OPERABLE, and if not, to ensure appropriate action is taken when the DG fuel oil storage tank volume is < a 7 day supply and > a 6 day supply. Currently the SONGS CTS do not contain an ACTION or SR when not in MODES 1, 2, 3, 4, 5 or 6 and irradiated fuel assembly movement is occurring. This change is acceptable because the Applicability of CTS and ITS 3.8.2 requires a DG to be OPERABLE during irradiated fuel assembly movement, but no fuel oil volume requirements are specified in CTS 3.8.3. This change corrects this oversight by ensuring the ACTIONS and SR for fuel oil storage tank volume are covered in all MODES or other specified conditions in the Applicability of LCO 3.8.1 and 3.8.2 when the DG is required to be OPERABLE. This change is designated as more restrictive because it adds additional requirements to the ITS that are not currently in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 1 - Removing Details of System Design and System Description, Including Design Limits) CTS SR 3.8.3.1 requires verifying that each fuel oil storage tank contains 48,400 gallons in MODE 1, 2, 3, or 4 and 43,600 gallons in MODE 5 or 6 every 31 days. When the requirements of CTS SR 3.8.3.1 are not met, CTS 3.8.3 Condition A or 3.8.3 Condition C is entered. CTS 3.8.3 Condition A is for when one or more DGs has a fuel volume < 48,400 gallons and > 41,800 gallons in storage tank during MODE 1, 2, 3, or 4. CTS 3.8.3 Condition C is for when one required DG has a fuel volume in the storage tank < 43,600 gallons and > 37,400 gallons during MODE 5 or 6. CTS SR 3.8.3.2 requires verifying that lubricating oil inventory is TS min limit every 31 days. When the requirements of CTS SR 3.8.3.2 are not met, CTS 3.8.3 Condition B is entered.

CTS 3.8.3 Condition B is for when one or more DGs with lube oil inventory < TS min and > TS inop. ITS 3.8.3 contains similar Surveillance Requirements but does not include the actual fuel volume or lube oil inventory. Instead the Surveillance Requirements verify that the fuel oil volume and lube oil inventory are greater than or equal to a 7 day supply. Furthermore, ITS 3.8.3 Condition A and Condition B are changed so that they are entered when the fuel volume in the storage tank or the lube oil inventory is less than a 7 day supply but greater than a 6 day supply. This changes the CTS by moving the specific values for the fuel volume and lube oil inventory to the Bases.

The removal of these details from the Technical Specifications is acceptable because this type of information is not necessary to provide adequate protection of public health and safety. The purpose of CTS SR 3.8.3.1 and SR 3.8.3.2 is to ensure that the DGs have sufficient fuel and lube oil to perform their safety function when the DGs are required to be OPERABLE. Furthermore, the purpose of CTS 3.8.3 ACTIONS A, B, and C are to specify the appropriate Required Actions and associated Completion Times when the DGs fuel volume and lube oil inventory are less than a 7 day supply but greater than a 6 day supply. ITS SR 3.8.3.1 and SR 3.8.3.2 will continue to ensure that sufficient fuel San Onofre Unit 2 and 3 Page 2 of 6 Attachment 1, Volume 11, Rev. 0, Page 184 of 437

Attachment 1, Volume 11, Rev. 0, Page 185 of 437 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR is contained in the fuel oil storage tank and lube oil is available for the DGs to perform their intended safety function when the DGs are required to be OPERABLE. Additionally, ITS 3.8.3 ACTIONS A and B will continue to specify the appropriate Required Actions and associated Completion Times when the DGs fuel volume and lube oil inventory are less than a 7 day supply but greater than a 6 day supply. Also, this change is acceptable because these types of details will be adequately controlled in the Technical Specification Bases.

Changes to the Bases are controlled by the Technical Specification Control Program in Chapter 5. The program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as less restrictive removal of detail change because details are being moved from the Technical Specifications to the ITS Bases.

LA02 (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 3.8.3.1 requires verifying that each fuel oil storage tank contains 48,400 gallons in MODE 1, 2, 3, or 4 and 43,600 gallons in MODE 5 or 6 every 31 days. CTS SR 3.8.3.2 requires verifying that lubricating oil inventory is TS min limit every 31 days. CTS SR 3.8.3.4 requires verifying that each DG air start receiver pressure is 175 psig every 31 days.

CTS SR 3.8.3.5 requires that accumulated water from each fuel oil storage tank is checked for and removed every 31 days. ITS SR 3.8.3.1, SR 3.8.3.2, SR 3.8.3.4, and SR 3.8.3.5 requires similar Surveillances and specifies the periodic Frequencies 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, provides a detailed description of the process to be followed when considering changes to a Surveillance Frequency.

NEI 04-10 will be reviewed and approved by the NRC separately from this Traveler. Therefore, the process is not discussed further here.

San Onofre Unit 2 and 3 Page 3 of 6 Attachment 1, Volume 11, Rev. 0, Page 185 of 437

Attachment 1, Volume 11, Rev. 0, Page 186 of 437 DISCUSSION OF CHANGES ITS 3.8.3, DIESEL FUEL OIL, LUBE OIL, AND STARTING AIR 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.