Text

Attachment 1, Volume 12, San Onofre Nuclear Generating Station - Improved Technical Specifications Conversion - ITS Section 3.9, Refueling Operations
	ML11251A106
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: ML11251A106 (170)
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Attachment 1, Volume 12, Rev. 0, Page 1 of 170 ATTACHMENT 1 VOLUME 12 SAN ONOFRE NUCLEAR GENERATING STATION IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.9 REFUELING OPERATIONS Attachment 1, Volume 12, Rev. 0, Page 1 of 170

Attachment 1, Volume 12, Rev. 0, Page 2 of 170 LIST OF ATTACHMENTS

1. ITS 3.9.1 - Boron Concentration

2. ITS 3.9.2 - Nuclear Instrumentation

3. ITS 3.9.3 - Containment Penetrations

4. ITS 3.9.4 - Shutdown Cooling and Coolant Circulation -

High Water Level

5. ITS 3.9.5 - Shutdown Cooling and Coolant Circulation -

Low Water Level

6. ITS 3.9.6 - Refueling Water Level Attachment 1, Volume 12, Rev. 0, Page 2 of 170

, Volume 12, Rev. 0, Page 3 of 170 ATTACHMENT 1 ITS 3.9.1, BORON CONCENTRATION , Volume 12, Rev. 0, Page 3 of 170

, Volume 12, Rev. 0, Page 4 of 170 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 4 of 170

Attachment 1, Volume 12, Rev. 0, Page 5 of 170 ITS Boron Concentration 3.9.1 A01 3.9 REFUELING OPERATIONS 3.9.1 Boron Concentration LCO 3.9.1 LCO 3.9.1 Boron concentrations of the Reactor Coolant System and the refueling canal shall be maintained within the limit specified in the COLR.

cavity A02 Applicability APPLICABILITY: MODE 6.

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

Only applicable to the refueling cavity when connected to L01 the RCS.

ACTIONS -------------------------------------------

CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. Boron concentration A.1 Suspend CORE Immediately L02 not within limit. ALTERATIONS.

AND 1 A.2 Suspend positive Immediately reactivity additions.

AND 2 A.3 Initiate actions to Immediately restore boron concentration to within limits.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.1.1 SR 3.9.1.1 Verify boron concentration is within limit 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months LA01 specified in the COLR.

In accordance with the Surveillance Frequency Control Program SAN ONOFRE--UNIT 2 3.9-1 Amendment No. 127 Attachment 1, Volume 12, Rev. 0, Page 5 of 170

Attachment 1, Volume 12, Rev. 0, Page 6 of 170 ITS Boron Concentration 3.9.1 A01 3.9 REFUELING OPERATIONS 3.9.1 Boron Concentration LCO 3.9.1 LCO 3.9.1 Boron concentrations of the Reactor Coolant System and the refueling canal shall be maintained within the limit specified in the COLR. A02 cavity Applicability APPLICABILITY: MODE 6. - - - - - - - - - - - - - - - - - - - NOTE- - - - - - - - - - - - - - - - - - -

Only applicable to the refueling cavity when connected to L01 the RCS.

ACTIONS -------------------------------------------

CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. Boron concentration A.1 Suspend CORE Immediately L02 not within limit. ALTERATIONS.

AND 1 A.2 Suspend positive Immediately reactivity additions.

AND 2 A.3 Initiate actions to Immediately restore boron concentration to within limits.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.1.1 SR 3.9.1.1 Verify boron concentration is within limit 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months LA01 specified in the COLR.

In accordance with the Surveillance Frequency Control Program SAN ONOFRE--UNIT 3 3.9-1 Amendment No. 116 Attachment 1, Volume 12, Rev. 0, Page 6 of 170

Attachment 1, Volume 12, Rev. 0, Page 7 of 170 DISCUSSION OF CHANGES ITS 3.9.1, BORON CONCENTRATION 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 3.9.1 provides requirements on the boron concentration of the Reactor Coolant System and the refueling canal. ITS 3.9.1 provides requirements on the boron concentration of the Reactor Coolant System and the refueling cavity.

This changes the CTS by changing the name of the refueling canal to the refueling cavity.

This change is acceptable because the technical requirements have not changed. The commonly used term to describe the area above the reactor vessel that is filled with borated water during activities and the adjacent area, below the plant elevation of the reactor vessel flange, is the refueling cavity. This change is designated as administrative because the technical requirements of the specifications have not changed.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 4 - Removal of LCO, SR, or other TS Requirement to the LCS, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS SR 3.9.1.1 requires verification that the boron concentration is within the limit specified in the COLR within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . ITS SR 3.9.1.1 requires the same Surveillance, but specifies the periodic Frequency as "In accordance with the Surveillance Frequency Control Program. This changes the CTS by moving the specified Frequency for the SR and the Bases for the frequency to the Surveillance Frequency Control Program.

The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are San Onofre Unit 2 and 3 Page 1 of 5 Attachment 1, Volume 12, Rev. 0, Page 7 of 170

Attachment 1, Volume 12, Rev. 0, Page 8 of 170 DISCUSSION OF CHANGES ITS 3.9.1, BORON CONCENTRATION performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. In addition:

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

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

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

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

Therefore, the process will not be discussed further here.

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

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

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

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

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

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

This change proposes to relocate various Frequencies for the performance of the Surveillance Requirements to a licensee-controlled program using an NRC approved methodology for control of the Surveillance Frequencies. The Surveillance Requirements themselves will remain in TS. This is consistent with other NRC approved TS changes in which the Surveillance Frequencies are not under NRC control, such as Surveillances that are performed in San Onofre Unit 2 and 3 Page 2 of 5 Attachment 1, Volume 12, Rev. 0, Page 8 of 170

Attachment 1, Volume 12, Rev. 0, Page 9 of 170 DISCUSSION OF CHANGES ITS 3.9.1, BORON CONCENTRATION accordance with the Inservice Testing Program or the Containment Leakage Rate Testing Program, where the Frequencies vary based on the past performance of the subject components. Thus, this proposed change meets criterion 1 above.

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

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

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

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

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

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

San Onofre Unit 2 and 3 Page 3 of 5 Attachment 1, Volume 12, Rev. 0, Page 9 of 170

Attachment 1, Volume 12, Rev. 0, Page 10 of 170 DISCUSSION OF CHANGES ITS 3.9.1, BORON CONCENTRATION

3. The proposed change maintains sufficient safety margins.

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

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

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

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

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

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

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

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

LESS RESTRICTIVE CHANGES L01 (Category 2 - Relaxation of Applicability) CTS 3.9.1 provides limits on the boron concentration of the Reactor Coolant System and the refueling canal when in MODE 6. ITS 3.9.1 modifies this requirement with a Note that states, "Only applicable to the refueling cavity when connected to the RCS." This changes the CTS by eliminating the applicability of the boron concentration limits on the refueling cavity when that volume is not connected to the RCS. See DOC A02 for discussion on changing "refueling canal" to "refueling cavity."

The purpose of CTS 3.9.1 is to ensure the boron concentration of the water surrounding the reactor fuel is sufficient to maintain the required SHUTDOWN MARGIN. This change is acceptable because the requirements continue to ensure the process variables are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. If the refueling cavity is not connected to the RCS (such as the when the reactor vessel head is on the reactor vessel), the boron concentration to this volume cannot affect the SHUTDOWN MARGIN. In addition, prior to connecting the refueling cavity to the RCS, a boron concentration verification (SR 3.9.1.1) will be performed (as required by SR 3.0.4) to ensure the newly connected portion cannot decrease San Onofre Unit 2 and 3 Page 4 of 5 Attachment 1, Volume 12, Rev. 0, Page 10 of 170

Attachment 1, Volume 12, Rev. 0, Page 11 of 170 DISCUSSION OF CHANGES ITS 3.9.1, BORON CONCENTRATION the boron concentration below the limit. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.

L02 (Category 4 - Relaxation of Required Action) The CTS 3.9.1 ACTION specifies the compensatory action for when the boron concentration requirement is not met. One of the compensatory actions is to suspend CORE ALTERATIONS.

Under similar conditions, ITS 3.9.1 does not require suspension of CORE ALTERATIONS. This changes the CTS by deleting the requirement to suspend CORE ALTERATIONS when the boron concentration requirement is not met.

The purpose of CTS 3.9.1 is to ensure the boron concentration of the water surrounding the reactor fuel is sufficient to maintain the required SHUTDOWN MARGIN. Thus, when the limit is not met, the CTS 3.9.1 ACTION suspends 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 of any fuel, sources, or reactivity control components 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 3.9.1 Required Action A.1 requires immediate suspension of positive reactivity changes. 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 dilution accident.

Therefore, since the only CORE ALTERATIONS that could affect the SHUTDOWN MARGIN are suspended by ITS 3.9.1 Required Action A.1, 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.

San Onofre Unit 2 and 3 Page 5 of 5 Attachment 1, Volume 12, Rev. 0, Page 11 of 170

Attachment 1, Volume 12, Rev. 0, Page 12 of 170 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 12 of 170

Attachment 1, Volume 12, Rev. 0, Page 13 of 170 U2/U3 CTS Boron Concentration 3.9.1 3.9 REFUELING OPERATIONS 3.9.1 Boron Concentration LCO 3.9.1 LCO 3.9.1 Boron concentrations of the Reactor Coolant System, [the refueling canal, 2

and the refueling cavity] shall be maintained within the limit specified in the COLR.

Applicability APPLICABILITY: MODE 6.

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

Only applicable to the refueling canal and refueling cavity when 2 connected to the RCS.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. Boron concentration not A.1 Suspend CORE Immediately within limit. ALTERATIONS. TSTF-471-A AND A.2 Suspend positive reactivity Immediately TSTF-471-A 1

additions.

AND A.3 Initiate action to restore Immediately TSTF-471-A 2

boron concentration to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.1.1 SR 3.9.1.1 Verify boron concentration is within the limit 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months specified in the COLR. TSTF-425-A In accordance with the Surveillance Frequency Control Program CEOG STS 3.9.1-1 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Amendment XXX Attachment 1, Volume 12, Rev. 0, Page 13 of 170

Attachment 1, Volume 12, Rev. 0, Page 14 of 170 JUSTIFICATION FOR DEVIATIONS ITS 3.9.1, BORON CONCENTRATION

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

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

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 14 of 170

Attachment 1, Volume 12, Rev. 0, Page 15 of 170 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 15 of 170

Attachment 1, Volume 12, Rev. 0, Page 16 of 170 Boron Concentration B 3.9.1 B 3.9 REFUELING OPERATIONS B 3.9.1 Boron Concentration BASES BACKGROUND The limit on the boron concentrations of the Reactor Coolant System the (RCS), the refueling canal, and refueling cavity during refueling ensures 5 that the reactor remains subcritical during MODE 6. Refueling boron concentration is the soluble boron concentration in the coolant in each of these volumes having direct access to the reactor core during refueling.

The soluble boron concentration offsets the core reactivity and is measured by chemical analysis of a representative sample of the coolant in each of the volumes. The refueling boron concentration limit is specified in the COLR. Unit procedures ensure the specified boron concentration in order to maintain an overall core reactivity of keff 0.95 during fuel handling, with control element assemblies (CEAs) and fuel assemblies assumed to be in the most adverse configuration (least negative reactivity) allowed by unit procedures.

GDC 26 of 10 CFR 50, Appendix A, requires that two independent reactivity control systems of different design principles be provided (Ref. 1). One of these systems must be capable of holding the reactor core subcritical under cold conditions. The Chemical and Volume Control or high pressure safety System (CVCS) is the system capable of maintaining the reactor 1 injection (HPSI) system subcritical in cold conditions by maintaining the boron concentration.

The reactor is brought to shutdown conditions before beginning operations to open the reactor vessel for refueling. After the RCS is cooled and depressurized and the vessel head is unbolted, the head is 5

is slowly removed to form the refueling cavity. The refueling canal and the refueling cavity are then flooded with borated water from the refueling storage water tank into the open reactor vessel by gravity feeding or by the use of 1 (i.e., low pressure safety the Shutdown Cooling (SDC) System pumps.

injection pumps and containment spray pumps)

The pumping action of the SDC System in the RCS and the natural circulation due to thermal driving heads in the reactor vessel and the refueling cavity mix the added concentrated boric acid with the water in the refueling canal. The SDC System is in operation during refueling (see LCO 3.9.4, "Shutdown Cooling and Coolant Circulation - High Water Level," and LCO 3.9.5, "Shutdown Cooling and Coolant Circulation - Low Water Level") to provide forced circulation in the RCS and assist in maintaining the boron concentrations in the RCS, the refueling canal, and 5 the refueling cavity above the COLR limit.

CEOG STS B 3.9.1-1 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 12, Rev. 0, Page 16 of 170

Attachment 1, Volume 12, Rev. 0, Page 17 of 170 Boron Concentration B 3.9.1 BASES APPLICABLE During refueling operations, the reactivity condition of the core is SAFETY consistent with the initial conditions assumed for the boron dilution ANALYSES accident in the accident analysis and is conservative for MODE 6. The boron concentration limit specified in the COLR is based on the core reactivity at the beginning of each fuel cycle (the end of refueling) and includes an uncertainty allowance.

The required boron concentration and the unit refueling procedures that demonstrate the correct fuel loading plan (including full core mapping) ensure the keff of the core will remain 0.95 during the refueling operation. Hence, at least a 5% k/k margin of safety is established during refueling.

transfer pool, During refueling, the water volume in the spent fuel pool, the transfer 1 tube canal, the refueling canal, the refueling cavity, and the reactor vessel form a single mass. As a result, the soluble boron concentration is relatively the same in each of these volumes.

The limiting boron dilution accident analyzed occurs in MODE 5 (Ref. 2).

A detailed discussion of this event is provided in B 3.1.1, SHUTDOWN MARGIN (SDM).

The RCS boron concentration satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The LCO requires that a minimum boron concentration be maintained in the RCS, the refueling canal, and refueling cavity while in MODE 6. The 5 boron concentration limit specified in the COLR ensures a core keff of 0.95 is maintained during fuel handling operations. Violation of the LCO could lead to an inadvertent criticality during MODE 6.

APPLICABILITY This LCO is applicable in MODE 6 to ensure that the fuel in the reactor vessel will remain subcritical. The required boron concentration ensures a keff 0.95. Above MODE 6, LCO 3.1.1, "SHUTDOWN MARGIN (SDM)," ensures that an adequate amount of negative reactivity is available to shut down the reactor and to maintain it subcritical.

The Applicability is modified by a Note. The Note states that the limits on this volume is boron concentration are only applicable to the refueling canal and the refueling cavity when those volumes are connected to the RCS. When 5 the refueling canal and the refueling cavity are isolated from the RCS, no potential path for boron dilution exists. is CEOG STS B 3.9.1-2 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 12, Rev. 0, Page 17 of 170

Attachment 1, Volume 12, Rev. 0, Page 18 of 170 Boron Concentration B 3.9.1 BASES ACTIONS A.1 and A.2 TSTF-471-A Continuation of CORE ALTERATIONS or positive reactivity additions (including actions to reduce boron concentration) is contingent upon maintaining the unit in compliance with the LCO. If the boron concentration of any coolant volume in the RCS, the refueling canal, or 5 the refueling cavity is less than its limit, all operations involving CORE TSTF-471-A ALTERATIONS or positive reactivity additions must be suspended immediately. Operations that individually add limited positive reactivity (e.g., temperature fluctuations from inventory addition or temperature control fluctuations), but when combined with all other operations affecting core reactivity (e.g., intentional boration) result in overall net negative reactivity addition, are not precluded by this action.

TSTF-Suspension of CORE ALTERATIONS and positive reactivity additions 471-A shall not preclude moving a component to a safe position.

A.3 2 TSTF-471-A In addition to immediately suspending CORE ALTERATIONS and positive reactivity additions, boration to restore the concentration must be initiated immediately.

In determining the required combination of boration flow rate and concentration, there is no unique design basis event that must be satisfied. The only requirement is to restore the boron concentration to its required value as soon as possible. In order to raise the boron concentration as soon as possible, the operator should begin boration with the best source available for unit conditions.

Once boration is initiated, it must be continued until the boron concentration is restored. The restoration time depends on the amount of boron that must be injected to reach the required concentration.

SURVEILLANCE SR 3.9.1.1 REQUIREMENTS This SR ensures the coolant boron concentration in the RCS, and connected portions of the refueling canal and the refueling cavity, is within 5 the COLR limits. The boron concentration of the coolant in each required volume is determined periodically by chemical analysis. Prior to re-connecting portions of the refueling canal or the refueling cavity to the 5 RCS, this SR must be met per SR 3.0.4. If any dilution activity has was occurred while the cavity or canal were disconnected from the RCS, this 5 SR ensures the correct boron concentration prior to communication with the RCS.

CEOG STS B 3.9.1-3 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 12, Rev. 0, Page 18 of 170

Attachment 1, Volume 12, Rev. 0, Page 19 of 170 Boron Concentration B 3.9.1 BASES SURVEILLANCE REQUIREMENTS (continued)

INSERT 1 A minimum Frequency of once every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is therefore a reasonable TSTF-amount of time to verify the boron concentration of representative 425-A samples. The Frequency is based on operating experience, which has shown 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to be adequate.

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

2. FSAR, Section [ ]. 1 2 U

15.4.1.4 San Onofre -- Draft Revision XXX 1

CEOG STS B 3.9.1-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 12, Rev. 0, Page 19 of 170

Attachment 1, Volume 12, Rev. 0, Page 20 of 170 B 3.9.1 TSTF-425-A INSERT 1 The Frequency is controlled under the Surveillance Frequency Control Program. 3

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

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

Insert Page B 3.9.1-4 Attachment 1, Volume 12, Rev. 0, Page 20 of 170

Attachment 1, Volume 12, Rev. 0, Page 21 of 170 JUSTIFICATION FOR DEVIATIONS ITS 3.9.1 BASES, BORON CONCENTRATION

1. Changes are made (additions, deletions, and/or changes) to the 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. The Bases words changed by TSTF-425 have been modified to state "The Frequency is controlled under the Surveillance Frequency Control Program." The Surveillance Frequency Control Program provides the details for how to change the Frequencies, thus the TSTF-425 words concerning operating experience, equipment reliability, and plant risk are not always true for each of the Frequencies.

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

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

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 21 of 170

Attachment 1, Volume 12, Rev. 0, Page 22 of 170 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 22 of 170

Attachment 1, Volume 12, Rev. 0, Page 23 of 170 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.9.1, BORON CONCENTRATION There are no specific NSHC discussions for this Specification.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 23 of 170

, Volume 12, Rev. 0, Page 24 of 170 ATTACHMENT 2 ITS 3.9.2, NUCLEAR INSTRUMENTATION , Volume 12, Rev. 0, Page 24 of 170

, Volume 12, Rev. 0, Page 25 of 170 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 25 of 170

Attachment 1, Volume 12, Rev. 0, Page 26 of 170 ITS Nuclear Instrumentation A01 3.9.2 3.9 REFUELING OPERATIONS 3.9.2 Nuclear Instrumentation LCO 3.9.2 LCO 3.9.2 Two source range monitors (SRMs) shall be OPERABLE.

Applicability APPLICABILITY: MODE 6.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One SRM inoperable. A.1 Suspend CORE Immediately L01 ALTERATIONS.

positive reactivity additions AND A.2 Suspend operations Immediately that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of LCO 3.9.1.

ACTION B B. Two SRMs inoperable. B.1 Initiate actions to Immediately restore one SRM to OPERABLE status.

AND B.2 Perform SR 3.9.1.1. 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months L02 AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter SAN ONOFRE--UNIT 2 3.9-2 Amendment No. 175 Attachment 1, Volume 12, Rev. 0, Page 26 of 170

Attachment 1, Volume 12, Rev. 0, Page 27 of 170 ITS Nuclear Instrumentation 3.9.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.2.1 SR 3.9.2.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months LA01 In accordance with the Surveillance Frequency Control Program SR 3.9.2.2 SR 3.9.2.2 -------------------NOTE--------------------

Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION. 24 months LA01 SAN ONOFRE--UNIT 2 3.9-3 Amendment No. 127 Attachment 1, Volume 12, Rev. 0, Page 27 of 170

Attachment 1, Volume 12, Rev. 0, Page 28 of 170 ITS Nuclear Instrumentation A01 3.9.2 3.9 REFUELING OPERATIONS 3.9.2 Nuclear Instrumentation LCO 3.9.2 LCO 3.9.2 Two source range monitors (SRMs) shall be OPERABLE.

Applicability APPLICABILITY: MODE 6.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One SRM inoperable. A.1 Suspend CORE Immediately L01 ALTERATIONS.

positive reactivity additions AND A.2 Suspend operations Immediately that would cause introduction into the RCS, coolant with boron concentration less than required to meet the boron concentration of LCO 3.9.1.

ACTION B B. Two SRMs inoperable. B.1 Initiate actions to Immediately restore one SRM to OPERABLE status.

AND B.2 Perform SR 3.9.1.1. 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months L02 AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter SAN ONOFRE--UNIT 3 3.9-2 Amendment No. 116,166 Attachment 1, Volume 12, Rev. 0, Page 28 of 170

Attachment 1, Volume 12, Rev. 0, Page 29 of 170 ITS Nuclear Instrumentation 3.9.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.2.1 SR 3.9.2.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months LA01 In accordance with the Surveillance Frequency Control Program SR 3.9.2.2 SR 3.9.2.2 -------------------NOTE--------------------

Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION. 24 months LA01 SAN ONOFRE--UNIT 2 3.9-3 Amendment No. 116 Attachment 1, Volume 12, Rev. 0, Page 29 of 170

Attachment 1, Volume 12, Rev. 0, Page 30 of 170 DISCUSSION OF CHANGES ITS 3.9.2, NUCLEAR INSTRUMENTATION ADMINISTRATIVE CHANGES A01 In the conversion of the San Onofre Nuclear Generating Station (SONGS)

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

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

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 4 - Removal of LCO, SR, or other TS Requirement to the LCS, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS SR 3.9.2.1 requires performance of a CHANNEL CHECK of source range instrumentation within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . CTS SR 3.9.2.2 requires performance of a CHANNEL CALIBRATION of source range instrumentation within 24 months. ITS SR 3.9.2.1 and SR 3.9.2.2 require similar Surveillances, but specify 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 San Onofre Unit 2 and 3 Page 1 of 5 Attachment 1, Volume 12, Rev. 0, Page 30 of 170

Attachment 1, Volume 12, Rev. 0, Page 31 of 170 DISCUSSION OF CHANGES ITS 3.9.2, NUCLEAR INSTRUMENTATION

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

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

Therefore, the process will not be discussed further here.

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

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

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

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

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

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

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

San Onofre Unit 2 and 3 Page 2 of 5 Attachment 1, Volume 12, Rev. 0, Page 31 of 170

Attachment 1, Volume 12, Rev. 0, Page 32 of 170 DISCUSSION OF CHANGES ITS 3.9.2, NUCLEAR INSTRUMENTATION

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

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

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

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

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

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

3. The proposed change maintains sufficient safety margins.

Conformance with this principle is assured since SSC design, operation, testing methods and acceptance criteria specified in the Codes and Standards or alternatives approved for use by the NRC, will continue to be met as described in the plant licensing basis (e.g., UFSAR, or Technical Specifications Bases). Also, the safety analysis acceptance criteria in the San Onofre Unit 2 and 3 Page 3 of 5 Attachment 1, Volume 12, Rev. 0, Page 32 of 170

Attachment 1, Volume 12, Rev. 0, Page 33 of 170 DISCUSSION OF CHANGES ITS 3.9.2, NUCLEAR INSTRUMENTATION licensing basis (e.g., UFSAR, supporting analyses, etc.) are met with the proposed change.

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

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

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

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

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

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

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

LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.9.2 ACTION A specifies the compensatory action for when one SRM is inoperable. One of the compensatory actions is to suspend CORE ALTERATIONS. Under similar conditions, ITS 3.9.2 does not require suspension of CORE ALTERATIONS but requires the suspension of positive reactivity additions. This changes the CTS by deleting the requirement to suspend CORE ALTERATIONS when one SRM is inoperable.

The purpose of the source range neutron flux monitors is to monitor core reactivity during refueling operations and provide a signal to the operators if an unexpected reactivity change occurs. Thus, when a source range neutron monitor is inoperable, CORE ALTERATIONS are suspended to preclude an unmonitored reactivity change. CORE ALTERATIONS is defined in CTS 1.1, in part, as "the movement or manipulation of any fuel, sources, reactivity control components, or other components, excluding control element assemblies (CEAs) withdrawn into the upper guide structure, affecting 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 3.9.2 Required Action A.1 requires immediate suspension of positive reactivity additions. 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 San Onofre Unit 2 and 3 Page 4 of 5 Attachment 1, Volume 12, Rev. 0, Page 33 of 170

Attachment 1, Volume 12, Rev. 0, Page 34 of 170 DISCUSSION OF CHANGES ITS 3.9.2, NUCLEAR INSTRUMENTATION 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 dilution accident. Therefore, since the only CORE ALTERATIONS that could affect the SHUTDOWN MARGIN are suspended by ITS 3.9.1 Required Action A.1, 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.

L02 (Category 3 - Relaxation of Completion Time) CTS 3.9.2 Required Action B.2 requires that if two SRMs are inoperable, then SR 3.9.1.1 shall be performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and then once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter. ITS 3.9.2 Required Action B.2 requires the same performance of SR 3.9.1.1 when two SRMs are inoperable but only on a once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months basis. This changes the CTS by not requiring the initial performance of SR 3.9.1.1 within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of entry into Condition B of LCO 3.9.2.

The purpose of CTS 3.9.2 Required Action B.2 is to verify the boron concentration when two SRMs are inoperable. The deletion of the initial performance of SR 3.9.1.1 within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of entry into Condition B of LCO 3.9.2 is acceptable because the accelerated performance of this SR is not warranted based on routine performance of SR 3.9.1.1 every 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and knowledge of stable conditions prior to the loss of the source range monitor. Additionally, RCS dilution events are recognizable through other means such as uncontrolled increases in pool water level. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

San Onofre Unit 2 and 3 Page 5 of 5 Attachment 1, Volume 12, Rev. 0, Page 34 of 170

Attachment 1, Volume 12, Rev. 0, Page 35 of 170 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 35 of 170

Attachment 1, Volume 12, Rev. 0, Page 36 of 170 U2/U3 CTS Nuclear Instrumentation 3.9.2 3.9 REFUELING OPERATIONS 3.9.2 Nuclear Instrumentation LCO 3.9.2 LCO 3.9.2 Two source range monitors (SRMs) shall be OPERABLE.

Applicability APPLICABILITY: MODE 6.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One [required] SRM A.1 Suspend CORE Immediately 2 TSTF-471-A inoperable. ALTERATIONS.

positive reactivity additions AND A.2 Suspend operations that Immediately would cause introduction of coolant into the RCS with boron concentration less than required to meet the boron concentration of LCO 3.9.1.

ACTION B B. Two [required] SRMs B.1 Initiate action to restore one Immediately 2 inoperable. SRM to OPERABLE status.

AND B.2 Perform SR 3.9.1.1. Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY TSTF-SR 3.9.2.1 SR 3.9.2.1 Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 425-A In accordance with the Surveillance Frequency Control Program CEOG STS 3.9.2-1 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Amendment XXX Attachment 1, Volume 12, Rev. 0, Page 36 of 170

Attachment 1, Volume 12, Rev. 0, Page 37 of 170 Nuclear Instrumentation U2/U3 CTS 3.9.2 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.9.2.2 SR 3.9.2.2 -------------------------------NOTE------------------------------

Neutron detectors are excluded from CHANNEL CALIBRATION.

TSTF-Perform CHANNEL CALIBRATION. [18] months 425-A In accordance with the Surveillance Frequency Control Program CEOG STS 3.9.2-2 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Amendment XXX Attachment 1, Volume 12, Rev. 0, Page 37 of 170

Attachment 1, Volume 12, Rev. 0, Page 38 of 170 JUSTIFICATION FOR DEVIATIONS ITS 3.9.2, NUCLEAR INSTRUMENTATION

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

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

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 38 of 170

Attachment 1, Volume 12, Rev. 0, Page 39 of 170 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Attachment 1, Volume 12, Rev. 0, Page 39 of 170

Attachment 1, Volume 12, Rev. 0, Page 40 of 170 Nuclear Instrumentation B 3.9.2 B 3.9 REFUELING OPERATIONS B 3.9.2 Nuclear Instrumentation BASES BACKGROUND The source range monitors (SRMs) are used during refueling operations to monitor the core reactivity condition. The installed SRMs are part of the Nuclear Instrumentation System (NIS). These detectors are located external to the reactor vessel and detect neutrons leaking from the core.

The use of portable detectors is permitted, provided the LCO requirements are met.

The installed SRMs are BF3 detectors operating in the proportional region of the gas filled detector characteristic curve. The detectors monitor the INSERT 1 neutron flux in counts per second. The instrument range covers five 1 decades of neutron flux (1E+5 cps) with a [5%] instrument accuracy. The detectors also provide continuous visual indication in the control room and an audible alarm to alert operators to a possible dilution accident.

The NIS is designed in accordance with the criteria presented in Reference 1.

2 If used, portable detectors should be functionally equivalent to the NIS SRMs.

APPLICABLE Two OPERABLE SRMs are required to provide a signal to alert the SAFETY operator to unexpected changes in core reactivity such as by a boron ANALYSES dilution accident or an improperly loaded fuel assembly. The safety analysis of the uncontrolled boron dilution accident is described in 3

Reference 2. The analysis of the uncontrolled boron dilution accident shows that normally available SHUTDOWN MARGIN would be reduced, but there is sufficient time for the operator to take corrective actions.

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

LCO This LCO requires two SRMs OPERABLE to ensure that redundant monitoring capability is available to detect changes in core reactivity.

APPLICABILITY In MODE 6, the SRMs must be OPERABLE to determine changes in core reactivity. There is no other direct means available to check core reactivity levels.

In MODES 2, 3, 4, and 5, the installed source range detectors and 5 circuitry are required to be OPERABLE by LCO 3.3.2, "RPS 1 Instrumentation Shutdown."

3.3.13, "Boron Dilution Monitoring Channels."

CEOG STS B 3.9.2-1 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 12, Rev. 0, Page 40 of 170

Attachment 1, Volume 12, Rev. 0, Page 41 of 170 B 3.9.2 1

INSERT 1 The installed SRMs are fission chamber detectors operating in the ionization region of the gas filled detector characteristic curve. The detectors monitor the neutron flux in counts per second.

The instrument range covers six decades of neutron flux (0.1-105 cps) with a 2% Equivalent Linear Full Scale (ELFS) (Reference 1). Two detectors provide continuous visual indication in the control room and one, as a minimum, an audible indication in the containment and control room.

Insert Page B 3.9.2-1 Attachment 1, Volume 12, Rev. 0, Page 41 of 170

Attachment 1, Volume 12, Rev. 0, Page 42 of 170 Nuclear Instrumentation B 3.9.2 BASES ACTIONS A.1 and A.2 With only one SRM OPERABLE, redundancy has been lost. Since these positive reactivity additions instruments are the only direct means of monitoring core reactivity TSTF-conditions, CORE ALTERATIONS and introduction of coolant into the 471-A RCS with boron concentration less than required to meet the minimum boron concentration of LCO 3.9.1 must be suspended immediately.

Suspending positive reactivity additions that could result in failure to meet the minimum 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 refueling boron concentration. This may result in an overall reduction in RCS boron concentration, but provides acceptable margin to maintaining subcritical operation. Performance of Required Action A.1 shall not preclude completion of movement of a component to a safe position.

B.1 With no SRM OPERABLE, action to restore a monitor to OPERABLE status shall be initiated immediately. Once initiated, action shall be continued until an SRM is restored to OPERABLE status.

B.2 With no SRM OPERABLE, there is no direct means of detecting changes TSTF-in core reactivity. However, since CORE ALTERATIONS and positive 471-A reactivity additions are not to be made, the core reactivity condition is stabilized until the SRMs are OPERABLE. This stabilized condition is determined by performing SR 3.9.1.1 to verify that the required boron concentration exists.

The Completion Time of once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient to obtain and analyze a reactor coolant sample for boron concentration and ensures that unplanned changes in boron concentration would be identified. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency is reasonable, considering the low probability of a change in core reactivity during this period.

CEOG STS B 3.9.2-2 Rev. 3.0, 03/31/04 1 San Onofre -- Draft Revision XXX Attachment 1, Volume 12, Rev. 0, Page 42 of 170

Attachment 1, Volume 12, Rev. 0, Page 43 of 170 Nuclear Instrumentation B 3.9.2 BASES SURVEILLANCE SR 3.9.2.1 REQUIREMENTS SR 3.9.2.1 is the performance of a CHANNEL CHECK, which is a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that the two indication channels should be consistent with core conditions. Changes in fuel loading and core geometry can result in significant differences between source range channels, but each channel should be consistent with its local conditions.

The Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is consistent with the CHANNEL CHECK TSTF-INSERT 2 Frequency specified similarly for the same instruments in LCO 3.3.1, 425-A "Reactor Protection System."

SR 3.9.2.2 SR 3.9.2.2 is the performance of a CHANNEL CALIBRATION every TSTF-18 months. This SR is modified by a Note stating that neutron detectors 425-A are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the source range neutron flux monitors consists of 1

obtaining the detector plateau or preamp discriminator curves, evaluating those curves, and comparing the curves to the manufacturer's data.

The 18 month Frequency is based on the need to perform this TSTF-INSERT 2 Surveillance under the conditions that apply during a plant outage. 425-A Operating experience has shown these components usually pass the Surveillance when performed on the 18 month Frequency.

REFERENCES 2 1. 10 CFR 50, Appendix A, GDC 13, GDC 26, GDC 28, and GDC 29. 1 U

15.4 1 2 3 2. FSAR, Section [ ].

1. DBD-SO23-470, Rev. 0, Excore Nuclear Instrumentation System, July 2, 1992. 1 San Onofre -- Draft Revision XXX CEOG STS B 3.9.2-3 Rev. 3.0, 03/31/04 1 Attachment 1, Volume 12, Rev. 0, Page 43 of 170

Attachment 1, Volume 12, Rev. 0, Page 44 of 170 B 3.9.2 TSTF-425-A INSERT 2 The Frequency is controlled under the Surveillance Frequency Control Program. 3

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

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

Insert Page B 3.9.2-3 Attachment 1, Volume 12, Rev. 0, Page 44 of 170

Attachment 1, Volume 12, Rev. 0, Page 45 of 170 JUSTIFICATION FOR DEVIATIONS ITS 3.9.2 BASES, NUCLEAR INSTRUMENTATION

1. Changes are made (additions, deletions, and/or changes) to the 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. The Bases words changed by TSTF-425 have been modified to state "The Frequency is controlled under the Surveillance Frequency Control Program." The Surveillance Frequency Control Program provides the details for how to change the Frequencies, thus the TSTF-425 words concerning operating experience, equipment reliability, and plant risk are not always true for each of the Frequencies.

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. Typographical error corrected. ISTS 3.3.2 (for SONGS the SRMs are covered by ITS 3.3.13, not ISTS 3.3.2) does not require SRMs to be OPERABLE in MODE 2.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 45 of 170

Attachment 1, Volume 12, Rev. 0, Page 46 of 170 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 12, Rev. 0, Page 46 of 170

Attachment 1, Volume 12, Rev. 0, Page 47 of 170 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.9.2, NUCLEAR INSTRUMENTATION There are no specific NSHC discussions for this Specification.

San Onofre Unit 2 and 3 Page 1 of 1 Attachment 1, Volume 12, Rev. 0, Page 47 of 170

, Volume 12, Rev. 0, Page 48 of 170 ATTACHMENT 3 ITS 3.9.3, CONTAINMENT PENETRATIONS , Volume 12, Rev. 0, Page 48 of 170

, Volume 12, Rev. 0, Page 49 of 170 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 12, Rev. 0, Page 49 of 170

Attachment 1, Volume 12, Rev. 0, Page 50 of 170 Containment Penetrations ITS A01 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Containment Penetrations LCO 3.9.3 LCO 3.9.3 The containment penetrations shall be in the following status:

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

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

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

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

2) The plant is in Mode 6 with at least 23 feet of water A03 above the reactor vessel flange,

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

4) Containment purge is in service, and

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

is capable of being A04

b. One door in each air lock closed; and

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

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

LA01

a. one personnel airlock door is OPERABLE, and b1. the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel, or A02 b2. defueled configuration with fuel in containment (i.e., fuel in refueling machine or upender).

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

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

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

INSERT 1 L01 Applicability APPLICABILITY: During CORE ALTERATIONS, L02 During movement of irradiated fuel assemblies within containment.

SAN ONOFRE--UNIT 2 3.9-4 Amendment No. 193 Attachment 1, Volume 12, Rev. 0, Page 50 of 170

Attachment 1, Volume 12, Rev. 0, Page 51 of 170 3.9.3 L01 INSERT 1

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

Penetration flow path(s) providing direct access from the containment atmosphere to the outside atmosphere may be unisolated under administrative controls.

Insert Page 3.9-4 Attachment 1, Volume 12, Rev. 0, Page 51 of 170

Attachment 1, Volume 12, Rev. 0, Page 52 of 170 Containment Penetrations ITS A01 3.9.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One or more A.1 Suspend CORE Immediately L02 containment ALTERATIONS.

penetrations not in required status. AND 1

A.2 Suspend movement of Immediately irradiated fuel assemblies within containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.3.1 SR 3.9.3.1 Verify each required containment 7 days LA02 penetration is in the required status.

In accordance with the Surveillance Frequency Control Program A05 INSERT 2 SR 3.9.3.2 SR 3.9.3.2 Verify each required containment purge and 24 months exhaust valve actuates to the isolation LA02 position on an actual or simulated actuation signal.

SAN ONOFRE--UNIT 2 3.9-5 Amendment No. 193 Attachment 1, Volume 12, Rev. 0, Page 52 of 170

Attachment 1, Volume 12, Rev. 0, Page 53 of 170 3.9.3 A05 INSERT 2

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

Not required to be met for containment purge and exhaust valve(s) in penetrations closed to comply with LCO 3.9.3.c.1.

Insert Page 3.9-5 Attachment 1, Volume 12, Rev. 0, Page 53 of 170

Attachment 1, Volume 12, Rev. 0, Page 54 of 170 Containment Penetrations ITS A01 3.9.3 3.9 REFUELING OPERATIONS 3.9.3 Containment Penetrations LCO 3.9.3 LCO 3.9.3 The containment penetrations shall be in the following status:

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

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

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

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

2) The plant is in Mode 6 with at least 23 feet of water A03 above the reactor vessel flange,

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

4) Containment purge is in service, and

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

is capable of being A04

b. One door in each air lock closed; and

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

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

LA01

a. one personnel airlock door is OPERABLE, and b1. the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel, or A02 b2. defueled configuration with fuel in containment (i.e., fuel in refueling machine or upender).

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

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

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

INSERT 1 L01 Applicability APPLICABILITY: During CORE ALTERATIONS, L02 During movement of irradiated fuel assemblies within containment.

SAN ONOFRE--UNIT 3 3.9-4 Amendment No. 116,184 Attachment 1, Volume 12, Rev. 0, Page 54 of 170

Attachment 1, Volume 12, Rev. 0, Page 55 of 170 3.9.3 L01 INSERT 1

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

Penetration flow path(s) providing direct access from the containment atmosphere to the outside atmosphere may be unisolated under administrative controls.

Insert Page 3.9-4 Attachment 1, Volume 12, Rev. 0, Page 55 of 170

Attachment 1, Volume 12, Rev. 0, Page 56 of 170 Containment Penetrations ITS A01 3.9.3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. One or more A.1 Suspend CORE Immediately L02 containment ALTERATIONS.

penetrations not in required status. AND 1

A.2 Suspend movement of Immediately irradiated fuel assemblies within containment.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.3.1 SR 3.9.3.1 Verify each required containment 7 days LA02 penetration is in the required status.

In accordance with the Surveillance Frequency Control Program A05 INSERT 2 SR 3.9.3.2 SR 3.9.3.2 Verify each required containment purge and 24 months exhaust valve actuates to the isolation LA02 position on an actual or simulated actuation signal.

SAN ONOFRE--UNIT 3 3.9-5 Amendment No. 116 Attachment 1, Volume 12, Rev. 0, Page 56 of 170

Attachment 1, Volume 12, Rev. 0, Page 57 of 170 3.9.3 A05 INSERT 2

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

Not required to be met for containment purge and exhaust valve(s) in penetrations closed to comply with LCO 3.9.3.c.1.

Insert Page 3.9-5 Attachment 1, Volume 12, Rev. 0, Page 57 of 170

Attachment 1, Volume 12, Rev. 0, Page 58 of 170 DISCUSSION OF CHANGES ITS 3.9.3, CONTAINMENT PENETRATIONS 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 3.9.3 allows both doors of the containment personnel air lock to be open provided, in part, that the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or defueled configuration with fuel in containment (i.e., fuel in refueling machine or upender). ITS 3.9.3 does not contain these restrictions.

This changes the CTS by not including the requirements that the plant is in MODE 6 with 23 feet of water above the fuel in the reactor vessel or defueled configuration with fuel in containment (i.e., fuel in refueling machine or upender).

This change is acceptable because the requirements are duplicative of the requirement in ITS LCO 3.9.6 which requires that refueling cavity water level to be maintained 23 feet above the top of the reactor vessel flange during movement of irradiated fuel assemblies within containment. Additionally, there is no need to state that the plant is in a defueled configuration with fuel in the containment. This change is designated as administrative because it does not result in technical changes to the CTS.

A03 CTS 3.9.3, in part, requires the equipment hatch to be closed and held in place by four bolts. The requirement is modified by a Note that allows the hatch to be open if certain conditions are met. One of the conditions is that the unit is in MODE 6 with a least 23 feet of water above the reactor vessel flange. ITS 3.9.3 includes the same equipment hatch requirement and includes the Note to allow the hatch to be open, but the specific condition concerning MODE 6 and the reactor water level is not included. This changes the CTS by deleting a conditional requirement for the equipment hatch to be open.

The purpose of the Note is to provide compensatory measures when the hatch is open. The specific condition concerning MODE 6 and the reactor water level is unnecessary, since this LCO and another LCO already require this condition to be met. Specifically, the unit must be in MODE 6 for this LCO to be applicable since CTS 3.9.3 and ITS 3.9.3 Applicability includes movement of irradiated fuel assemblies within containment. Since movement of irradiated fuel assemblies within containment can only occur when the unit is in MODE 6, the specific requirement in the Note is redundant and unnecessary. The second part of the Note required the water level to be at least 23 feet above the reactor vessel flange. Both CTS 3.9.6 and ITS 3.9.6 already specify this restriction, and the Applicability of CTS 3.9.6 and ITS 3.9.6 is during movement of irradiated fuel assemblies within containment, exactly like the Applicability of this LCO.

Therefore, this part of the Note is also redundant and unnecessary. Therefore, San Onofre Unit 2 and 3 Page 1 of 8 Attachment 1, Volume 12, Rev. 0, Page 58 of 170

Attachment 1, Volume 12, Rev. 0, Page 59 of 170 DISCUSSION OF CHANGES ITS 3.9.3, CONTAINMENT PENETRATIONS deleting this condition form the Note is acceptable and considered administrative since the technical requirements are not changing.

A04 CTS 3.9.3 requires, in part, one door in each air lock to be closed or allows both doors of the containment personnel airlock to be open provided one personnel air lock door is OPERABLE. ITS 3.9.3 requires that one door in each air lock is capable of being closed. This changes the CTS by replacing the prescriptive requirements for control of the air lock doors with a more general requirement that the air lock doors must be capable of being closed.

This change is acceptable because the CTS requirements have not changed. A door that is closed is a door that is also capable of being closed. The ITS requirements preserve the intent of the CTS. This change is designated as administrative because it does not result in technical changes to the CTS.

A05 CTS SR 3.9.3.2 requires, in part, verifying that each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal. ITS SR 3.9.3.2 requires this same verification but is modified by a Note that states that SR 3.9.3.2 is not required to be met for containment purge and exhaust valve(s) that are closed to comply with LCO 3.9.3.c.1. This changes the CTS by adding a Note that the SR is not required to be met for containment purge and exhaust valve(s) in penetrations that are closed to comply with ITS LCO 3.9.3.c.1.

The purpose of CTS SR 3.9.3.2 is to verify that the equipment required to meet the LCO is OPERABLE. LCO 3.9.3.c provides two options to meet the LCO requirement: either the penetrations must be isolated (LCO 3.9.3.c.1) or the automatic actuation signal must be capable of closing the valves (LCO 3.9.3.c.2).

Thus, when LCO 3.9.3.c.1 is being met, LCO 3.9.3.c.2 is not required, and its associated SR (SR 3.9.3.2) is also not required, per SR 3.0.1. Therefore, the addition of this Note is editorial and acceptable. This change is designated as administrative since it does not result in any technical changes.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS LCO 3.9.3.b contains a Note which states, in part, that both doors of the containment personnel airlock may be open provided that one personnel airlock door is OPERABLE. ITS 3.9.3.b does not contain this Note. This changes the CTS by moving the information that both doors can be San Onofre Unit 2 and 3 Page 2 of 8 Attachment 1, Volume 12, Rev. 0, Page 59 of 170

Attachment 1, Volume 12, Rev. 0, Page 60 of 170 DISCUSSION OF CHANGES ITS 3.9.3, CONTAINMENT PENETRATIONS open provided that one personnel airlock door is OPERABLE to the ITS Bases.

See DOC A02 for additional changes to the CTS 3.9.3 Note. Specifically, the term OPERABLE is not used in the Bases, but it is changed to capable of being closed.

This removal of these details, which are related to procedural details for meeting Technical Specification requirements, from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. ITS LCO 3.9.3.b continues to require one door in each airlock to be capable of being closed. Also, this change is acceptable because the removed information 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 because information relating to procedural details for meeting Technical Specification requirements is being removed from the Technical Specifications.

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 3.9.3.1 requires a verification that each required containment penetration is in the required status every 7 days. CTS SR 3.9.3.2 requires a verification that each required containment purge and exhaust valve actuates to the isolation position on an actual or simulated actuation signal every 24 months. ITS SRs 3.9.3.1 and 3.9.3.2 require the same verifications but specify 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, Rev. 1, provides a detailed description of the process to be followed when considering changes to a Surveillance San Onofre Unit 2 and 3 Page 3 of 8 Attachment 1, Volume 12, Rev. 0, Page 60 of 170

Attachment 1, Volume 12, Rev. 0, Page 61 of 170 DISCUSSION OF CHANGES ITS 3.9.3, CONTAINMENT PENETRATIONS Frequency. NEI 04-10, Rev. 1, has been reviewed and approved by the NRC.