ML13333A144

Suppl 2 to Amend Application 188 to License DPR-13,changing Tech Spec 3.3 Re Safety Injection & Containment Spray Sys & 3.5.5 Re Containment Isolation Instrumentation to Reflect Mods Made During Cycle 11 Refueling Outage

ML13333A144
Person / Time
Site:	San Onofre
Issue date:	09/09/1991
From:	Morgan H SOUTHERN CALIFORNIA EDISON CO.
To:
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ML13326A810	List: ML13326A809 ML13333A144 ML13333A145
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NUDOCS 9109110226
Download: ML13333A144 (53)

Text

BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION Application of SOUTHERN CALIFORNIA EDISON

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COMPANY and SAN DIEGO GAS & ELECTRIC COMPANY

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DOCKET NO. 50-206 for a Class 104(b) License to Acquire,

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Possess, and Use a Utilization Facility as

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Amendment Application Part of Unit No. 1 of the San Onofre Nuclear

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No. 188, Supplement 2 Generating Station

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SOUTHERN CALIFORNIA EDISON COMPANY and SAN DIEGO GAS & ELECTRIC COMPANY, pursuant to 10 CFR 50.90, hereby submit Amendment Application No. 188, Supplement 2.

This amendment application consists of Proposed Change No. 151, Revision 2, to Provisional Operating License No. DPR-13. The proposed change will revise Section 3.3, "Safety Injection and Containment Spray Systems," Section 3.5.5, "Containment Isolation Instrumentation," Table 4.1.2, "Minimum Equipment Check and Sampling," Section 4.2, "Safety Injection and Containment Spray System," and Section 4.4 "Emergency Power System Periodic Testing." of the Appendix A, Technical Specifications for San Onofre Nuclear Generating Station (SONGS),

Unit 1.

Proposed Change No. 151, Revision 2, modifies the Technical Specifications incorporated in Provisional Operating License No. DPR-13 as Appendix A by adding new surveillance test requirements, and generally revising the format and content of the affected Technical Specification sections in accordance with the Standard Technical Specifications and recent discussions with NRR.

9109110226 910909 PDR ADOCK 05000206 p

PDR

-2 The level of detail contained in Section 3.3 has been reduced io make the specification less complicated. The proposed change revises Section 3.3 to reflect recent ECCS modifications which train align equipment, and adds system flow path requirements.

Based on the significant hazards analysis provided in the Description and Significant Hazards Consideration Analysis of Proposed Change No. 151, Supplement 2, it is concluded that (1) the proposed change does not involve a significant hazards consideration as defined in 10 CFR 50.92, and (2) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed change.

-3 Respectfully submitted, SOUTHERN CALIFORNIA EDISON COMPANY By:

H. E. Morgan

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Vice President and Site Manager State of California County of Orange-San Diego On Sept. 9.

1991 before me, Linda L. Rulon personally appeared H. E. Morgan

, personally known to me to be the person whose name is subscribed to the within instrument.rnd.acknowledged to me that he executed the same in his authorized capacity, and that by his signature on the instrument the person, or the entity upon behalf of which the person acted, executed the instrument.

WITNESS my hand and official seal.

OFFICIAL SEAL LINDA L. RULON Signature Noa ic-Calfnia

) ~on' My Comm. Exp. Mar. 4,1992 James A. Beoletto Attorney for Southern California Edison Company By:

J a s A.ol eTo

DESCRIPTION AND SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS OF PROPOSED CHANGE NUMBER 151, REVISION 2, TO THE TECHNICAL SPECIFICATIONS PROVISIONAL OPERATING LICENSE NO. DPR-13 This is a request to revise Technical Specifications Section 3.3, "Safety Injection and Containment Spray Systems," Section 3.5.5, "Containment Isolation Instrumentation," Table 4.1.2, "Minimum Equipment Check and Sampling," Section 4.2, "Safety Injection and Containment Spray System," and Section 4.4, "Emergency Power System Periodic Testing" of the Appendix A, Technical Specifications for San Onofre Nuclear Generating Station (SONGS),

Unit 1. Revision 2, enclosed, updates our submittal of August 31, 1990, for modifications made during the Cycle 11 refueling outage, and incorporates NRR comments.

EXISTING TECHNICAL SPECIFICATIONS See Attachment 1.

PROPOSED TECHNICAL SPECIFICATIONS See Attachment 2.

DESCRIPTION The proposed change provides updated Technical Specifications for the operation of the Emergency Core Cooling Systems (ECCS).

The revision will improve and refine the existing specifications by providing:

Use of the Westinghouse Standard Technical Specifications (STS) as a basis and format of the new specifications.

New specifications for ECCS functions and components.

Resolution of discrepancies within the existing specifications, and a consolidation of previous commitments with planned changes.

The guidance of the STS has been followed as a basis for train alignment of the ECCS, Limiting Conditions of Operation (LCO), surveillance and action statement requirements. SONGS 1 has a unique arrangement of common flow paths and components with multiple ECCS functions. As a result, many of the more general requirements of the STS have been expanded into detailed requirements in the proposed change. These additional requirements are at the component level to assure the alignment of the ECCS is consistent with the design basis and current single failure analysis.

New specifications are proposed for systems and components not included in the existing Technical Specifications. The lack of requirements for the recirculation system in the existing specifications contributed to a recent Notice of Violation'. In response to the NOV, we have included in the proposed change specific requirements for the operation of the recirculation system. The lack of specific requirements and action statements has also resulted in the need to rely on Technical Specification 3.0.3, and resulted in plant shutdowns and other actions which would not normally be required for a

-2 standard plant. The proposed change will correct this by replacing existing specifications with LCOs and action statements based on the STS. In most circumstances a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action statement will be applied. The proposed change will satisfy long term corrective actions described in Licensee Event Reports (LER),

LER 1-89-018?, LER 1-89-024, and LER 1-89-025'.

The proposed change will resolve potentially non-conservative requirements for the operation of the Containment Spray System and correct discrepancies in the current specifications. Specification 3.5.5, "Containment Isolation Instrumentation," is being changed to correct the action statement time limit for the safety injection sequencer subchannel which conflicts with the action statement for the sequencer. Specification 4.2, "Safety Injection and Containment Spray System," will incorporate STS containment inspections and ECCS surveillance requirements based on the STS. This supplement also updates surveillance requirements in Table 4.1.2, "Minimum Equipment check and Sampling," and Specification 4.4, "Emergency Power System Periodic Testing."

Also included are several administrative changes to update the terminology and references in the specifications.

This revision updates our submittal of August 31, 1990 to incorporate modifications made during the Cycle 11 refueling outage and comments made by NRR during their review. A number of minor editorial changes and corrections were also included. The bases sections have been changed to address implantation of the new specifications.

The discussion section is organized as follows:

• A. Background This briefly describes why the proposed change is being submitted.

• B. Sections of the Technical Specifications Affected by the Proposed Change. This section summarizes the changes.

• C. Detailed Description of Changes to Technical Specifications.

This section reviews each change in detail.

The Significant Hazards Analysis is found at the end of Section C.

DISCUSSION A. Background The proposed change implements previous commitments' 2,3.4 to incorporate operability requirements for the Recirculation and Containment Spray Systems into the Specifications. The existing operability requirements for many of the ECCS components and flow paths do not provide sufficient action statements, since the existing specifications were written before the STS were issued. Without specific action statements it has become necessary to enter Specification 3.0.3 whenever a component becomes inoperable, even for a brief period of time. Recently this resulted in the need to obtain a temporary Waiver of Compliance8 for maintenance and testing of a redundant train of

-3 components which would normally have a 72-hour action statement under the STS.

The proposed change updates the specifications by providing specific operability requirements for the ECCS and action statements based on the Westinghouse STS. The proposed change uses new information resulting from recent design basis efforts and the single failure analysis as a basis. It also is consistent with the modifications which were installed in Cycle 11.

B. Sections of the Technical Specifications Affected by the Proposed Change Existing Technical Specification Section 3.3, "Safety Injection and Containment Spray Systems," specifies the operability requirements for the safety features needed to mitigate the effects of design basis accidents.

Operability requirements for hot leg and cold leg recirculation flow paths are consistent with the analysis contained in the Updated Final Safety Analysis Report (UFSAR), Section 15, and are described in UFSAR Sections 6.1, 6.2, and 6.3.

Modification of Existing Specifications The proposed change organizes Technical Specification Section 3.3 by ECCS sub systems and MODE operability requirements within each subsection. The new action statements and section titles are based on the STS. The revised specifications take into consideration the flow paths and train-alignment.

The original submittal of August 31, 1990, contained a number of component specific LCOs. Based on our discussions with NRR during the review of the original submittal, we have revised the proposed specifications to utilize flow path functional descriptions similar to the STS, and have deleted most of the references to specific components.

The existing Section 3.3, "Safety Injection and Containment Spray Systems,"

currently has five subsections which will be revised into eight subsections as follows:

The existing Section 3.3.1, "Operating Status," provides the operability requirements for the ECCS components, assuring that adequate engineered safeguards are operable in the appropriate modes of operation. The requirements of this section are being divided into two new sections based on the isolation of the safety injection and feedwater pumps at an RCS pressure of 600 psig. The two new sections are:

• Section 3.3.1, "ECCS Subsystems-RCS Pressure a 600 psig"

• Section 3.3.2, "ECCS Subsystems-RCS Pressure < 600 psig"

-4 The existing Section 3.3.2, "Shutdown Status," requires the establishment of two positive barriers between the safety injection and feedwater pumps of the Safety Injection System (SIS) and the Reactor Coolant System (RCS).

Isolation of the SIS is currently required when the RCS pressure is less than 500 psig to prevent an inadvertent injection of feedwater into the RCS, and preclude the potential for RCS overpressurization, or boron dilution. A change to permit operation of the feedwater pump breakers in the test position, while the pumps are isolated, is being made to be consistent with surveillance requirements.

Cross-references to other specifications are also being corrected. The section will be retitled Section 3.3.3, "Isolation of the RCS from the Feedwater/Condensate and Safety Injection Systems." The specifications requirements were changed to delete the requirement for the RCS to be water solid before overpressurization protection is required. A new provision was also added to allow a blind flange to serve as an alternate positive barrier.

The existing Section 3.3.3, "Minimum Boron Concentration in the Refueling Water Storage Tank (RWST) and Safety Injection (SI) Lines and Minimum RWST Water Volume," specifies the inventory and concentration of borated water required to maintain the operability of the RWST and the safety injection lines. This section has minor changes to specification cross-references and will be renumbered Section 3.3.4, with the title revised.

The existing Section 3.3.4, "Minimum Solution Volume Hydrazine Concentration in the Hydrazine Tank," assures the operability of the hydrazine supply system required for post-accident iodine removal.

This section has been revised in accordance with the STS and has been combined with the Containment Spray System specifications in Section 3.3.5, "Containment Spray System."

The existing Section 3.3.5, "Primary Coolant System Pressure Isolation Valves," specifies the acceptance limits for operation of the RCS check valves. These check valves prevent backflow of the RCS into the safety injection system, and prevent overpressurization of the SIS from the RCS. Editorial changes were made to the wording of the specification and action statement requirements. The valve numbers have been revised in accordance with new designations and the section renumbered as 3.3.6, with the same title.

New Section 3.3.7, "Component Cooling Water System," has been added to provide operability requirements for the Component Cooling Water System.

This revision replaces the previously proposed Section 3.3.8, "Status of ECCS Components," with new Section 3.3.8, "Recirculation Loop Outside Containment Effective Leakage," which contains requirements previously located in Section 3.3.1.

The section "Status of ECCS Components" was deleted to reduce the complexity of the proposed specifications.

-5 In addition to the revisions to Section 3.3, Section 3.5.5, "Containment Isolation Instrumentation," is being revised to correct conflicting action statements on sequencer operability.

Table 4.1.2, "Minimum Equipment Check and Sampling," has been revised to include a surveillance of the hydrazine tank volume and update mode requirements.

Section 4.2.1, "Safety Injection and Containment Spray System Periodic Testing," has been revised to include additional test requirements for the ECCS, and containment inspection requirements consistent with the STS. Additional surveillance requirements for ECCS System instrumentation have been added in this revision.

Section 4.4, "Emergency Power System Periodic Testing," was updated to require verification of component actuation during loss-of-power testing of the SI System.

C. Detailed Description of Changes to Technical Specifications

1. DELETION OF SPECIFICATION 3.3.1.C - 3.0.3 ENTRY DUE TO SURVEILLANCE TESTING Existing Technical Specification 3.3.1.C requires surveillance testing of redundant components or trains prior to entry into the associated action statements. As described in LER 1-89-0182, "Voluntary Entry into Technical Specification 3.0.3 in order to Perform Surveillance of Containment Spray System Pump due to Inadequate TS," this requirement has placed the unit in a non-conservative configuration, and conflicts with the intent of the Technical Specifications. As reported in the LER, one containment spray pump had become inoperable. To comply with existing Specification 3.3.1.C, the Containment Spray System was required to be isolated during the test of the redundant pump. The STS do not require a surveillance of the redundant ECCS trains, or equipment, prior to removing a component from service. Therefore, the proposed change will delete Specification 3.3.1.C, to reduce the potential for non-conservative actions and to be consistent with the STS.

2. INCORPORATION OF 72 HOUR ACTION STATEMENTS The STS typically allow redundant ECCS components to be inoperable for a period not exceeding 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. During this time, the single failure criterion is relaxed. Existing Specification 3.3 does not contain sufficient train aligned action statements for the ECCS, since it was written prior to the issuance of the STS. For example, under the current Technical Specifications, when a safety injection or feedwater pump is removed from service, or a redundant flow path becomes inoperable, the plant enters Specification 3.0.3.

This requires initiation of a plant shutdown within one hour.

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-6 Accordingly, the proposed change provides appropriate 72-hour action statements for redundant ECCS components. The SIS operability requirements are organized by pump trains and flow paths to accommodate the unique design features of SONGS 1. This will prevent unnecessary entry into Action Statement 3.0.3 in the event redundant features of the ECCS are out-of-service. It also will reduce the potential for unnecessary plant shutdowns and the associated reports.

The proposed specifications for flow paths state that required valves and instruments must also be operable. Existing Specifications 3.3.1.A.b(3), for valves and interlocks, and 3.3.1.A.(1), for RWST level trip interlocks, are encompassed by this new requirement and therefore have been deleted. A surveillance requirement for the RWST level instruments was added to Specification Section 4.2.

3. SPECIFICATIONS 3.3.1 AND 3.3.2 ECCS SUBSYSTEMS - RCS PRESSURE L 600 psiq ECCS SUBSYSTEMS - RCS PRESSURE < 600 psiq

a. Safety Injection System As described in the UFSAR Section 15.16, the worst case Loss of Coolant Accident (LOCA) occurs at 100% power. Two redundant ECCS trains are required to protect the core, and to withstand an assumed worst single active failure of one of the two trains. Both ECCS trains are also required for a Main Steam Line Break (MSLB), with an assumed worst single active failure at both hot zero power and 100% power (UFSAR Section 15.2).

Section 3.3.1, "Safety Injection and Containment Spray Systems; Operating Status," has been revised to require two redundant safety injection pump trains and associated flow paths and components to be operable in MODES 1, 2, and 3 (RCS pressure above or equal to 600 psig).

Under the existing specifications, the safety injection and feedwater pumps are only required in MODES 1 and 2, and must be isolated from the RCS at an RCS pressure of 500 psig to provide overpressure protection and preclude a boron dilution event (UFSAR Section 6.3.2.8.2). The STS require two trains of safety injection capability until MODE 4 entry (3500F). In the proposed specifications, the transition is made at an RCS pressure of 600 psig, rather than MODE 4, to allow the safety injection and feedwater pumps to be isolated, as designed, prior to 500 psig. A pressure of 600 psig was chosen to allow operating personnel a 100 psi band to perform the isolation prior to reaching the required isolation point at 500 psig. During the limited time the RCS is in transition from 600 psig to 350*F, and through MODE 4, cold leg injection is under manual control and would be provided by the charging pump through the cold leg injection/recirculation valves (FCV-1115 D,EF).

SII

-7 The proposed change will define a single safety injection pump train to consist of a safety injection pump and a feedwater pump. The revised operability requirements speci.fy two redundant safety injection pump trains in MODES 1, 2, and 3 (above, or equal to 600 psig).

The existing specifications only require the pump trains to be operable when the reactor is critical.

Existing Specification 3.3.1.(3), which requires associated valves and interlocks, has been deleted and replaced by requiring valves and instruments be operable for the ECCS flow paths.

A footnote was added to block the automatic actuation logic of the Safety Injection System in MODE 3 less than or equal to 1900 psig. This will prevent safety injection actuation during shutdown due to the normal reduction in primary system pressure. The footnote was added to be consistent with existing Specification 3.7 which allows blocking of the sequencer automatic safety injection function. Protection from an inadvertent safety injection is provided by the pressurizer safety valves. The potential pressure increase due to operation of the primary safety injection path, via the safety injection and feedwater pumps is limited to the shut-off head of the feedwater pumps.

b. Recirculation System The Recirculation System operability requirements have been divided into hot leg and cold leg recirculation paths. A flow path for secondary recirculation has been added in this revision. New sections 3.3.1 and 3.3.2 provide the detailed operability requirements for the recirculation flow paths and components. We committed to add requirements for the Recirculation System to the Technical Specifications in our previous response to a Notice of Violation (NOV)1. The new requirements will assure both the cold leg, hot leg, and secondary recirculation paths are maintained operable, as described in UFSAR Section 6.3.3.4. Action statements provided for the flow paths and pump trains are based on the STS.

In many instances, the failure of either a hot leg or cold leg recirculation path, or associated component, under the existing specifications, requires entry into Specification 3.0.3 due to the lack of specific action statements.

The proposed changes will enable the removal of the existing administrative controls for recirculation components which require entry into Specification 3.0.3.

The Recirculation System returns the containment spray and break flow from the containment sump to the RCS and Containment Spray System following the initial cold leg injection phase during post-LOCA conditions. The hot leg recirculation prevents boron precipitation in the RCS for long term post-LOCA cooling. The Recirculation System consists of redundant recirculation pump trains, the cold leg recirculation paths, and hot leg recirculation paths. A recirculation pump, a charging pump, and a refueling water pump constitute a recirculation pump train.

-8 The normal hot leg recirculation path directs flow from the recirculation pump common discharge header through the recirculation heat exchanger. Flow is through either of two parallel valves, MOV-1100B and MOV-1100D, to the charging pumps. Cycle 11 modifications added a redundant VCT outlet isolation valve (MOV-1100E) in series with the existing valve (MOV-1100C) and associated redundant level instrumentation. A common discharge header supplies charging pump flow to the Loop B hot leg via pressurizer auxiliary spray line. The normal hot leg path valves which do not have a redundant parallel valve, can be powered from either electrical train and therefore are not affected by a single electrical failure.

The alternate hot leg recirculation path serves as a back-up to the normal hot leg recirculation flow path in the event of a mechanical failure. The path takes flow from the recirculation heat exchanger and the refueling water pumps through either of two Residual Heat Removal (RHR) heat exchangers via either MOV-822A or MOV-822B. A cross-tie valve connects the containment spray header to the letdown line via manual isolation valve LDS-020. Manual bypass valve RHR-004 allows flow around the east RHR pump, and through the RHR inlet isolation valves, MOV-813 and MOV-814, to the Loop C hot leg. The manual valve is locked open during power operation and is located inside the containment, which prevents access by unauthorized personnel.

The alternate path requires both electrical trains (Trains A and B) to operate the series isolation valves.

The secondary recirculation path has also been included in the proposed specifications. This path is for long term cooling after a Main Steam Line Break (MSLB) inside containment which could disable portions of the RHR system that are not environmentally qualified. The recirculation pumps supply water from the containment sump through the recirculation heat exchanger to the refueling water pumps, which return water to the RWST. The safety injection and feedwater pumps are then aligned to supply water to the secondary side of the steam generators, via the feedwater bypass valves. The equipment required for secondary recirculation is covered by the other specifications in this section, however, the flow path has been added to ensure it is maintained.

This section has not been incorporated into the specifications for RCS pressure less than 600 psig because of the low potential for an MSLB at low pressures and the limited time the plant would operate in this condition prior to entering MODE 4.

The charging pumps are required by the proposed specifications for both the hot leg primary path and cold leg path of recirculation. Although a charging pump is started by a safety injection signal, charging flow is not credited for safety injection in the safety analysis, as described in UFSAR Section 6.3.

-9 Due to limitations of the current Overpressure Mitigation Analysis, restrictions have been placed.on the operation of the high flow cold leg recirculation valves to the cold legs (FCV-1115D,E,F). Currently when RHR is in operation, below an RCS temperature of 350*F, it is necessary to isolate at least two of these.valves. An analysis has been performed for normal operation and verified that adequate flow is available to remove core decay heat in cold leg recirculation via two of the low flow valves (FCV-1115A,B,C) independent of normal charging flow via FCV-1112.

The proposed specification requires the operability of the charging pump through MODE 4. The refueling water pumps, normally used for containment spray, also supply the alternate hot leg recirculation path. Operability of both refueling pumps is required by Specification 3.3.5 for containment spray in MODES 1 through 4. The basis of Section 3.3.1 is provided to clarify the recirculation flow paths.

The proposed change will delete existing Specification 3.3.1.D which permits the indefinite inoperability of one recirculation pump and requires closure of containment spray flow limiting valves CV-517 and CV-518 (see "Containment Spray").

The operability requirements for these valves are discussed in the description of the containment spray subsection. The associated action statements are consistent with the STS and are based on the redundancy of the common flow paths within each of the hot and cold leg recirculation paths.

The proposed Section 3.3.2 will require one operable recirculation train in MODE 3 (RCS pressure below 600 psig), and in MODE 4. Only one train is required as the STS provides relaxation of single failure consideration for the ECCS in MODE 4 on the basis of the stable reactivity condition of the reactor and the limited core cooling requirements.

4.

SPECIFICATION 3.3.3 ISOLATION OF THE RCS FROM THE FEEDWATER/CONDENSATE AND SAFETY INJECTION SYSTEMS The proposed change will clarify the ambiguity in operability requirements for the primary safety injection path that currently exists between Sections 3.3.2 and 3.3.3. Existing Section 3.3.2 requires positive isolation of the primary safety injection path (MOVs-850A,850B,850C) via the feedwater/safety injection pumps below 500 psig, while existing Section 3.3.3 applies in "... Modes 1 through 4, or as described in Specification 3.2."

Existing Specification 3.3.3 addresses the boron concentration and capacity of the RWST and connecting safety injection line. When the safety injection line is permitted to be isolated under existing Specification 3.3.2, it is not in service, and therefore the specification for boron concentration does not apply. A note has been added to the proposed change for the operability requirements for the safety injection line to clarify that the provisions do not apply when the line is permitted to be removed from operation.

-10 During accident conditions the feedwater pumps are aligned to the RCS for safety injection. At low RCS pressures it is necessary to isolate the pumps from the RCS to preclude an inadvertent injection of feedwater that could dilute the RCS boron concentration, or cause an overpressurization event.

Existing Specification 3.3.2, "Shutdown Status," requires isolation of the RCS from the feedwater system when RCS pressure is less than 500 psig. The proposed change, contained in new Specifications 3.3.2 and 3.3.3, permits isolation of the safety injection/feedwater pumps from the RCS at 600 psig to allow the operators sufficient time to establish the two positive barriers required prior to reaching 500 psig. The applicability section has been revised to provide MODE requirements, and the specification additionally clarified for dilution and overpressurization protection. The requirement to provide two positive barriers from the RCS when it is water solid below 500 psig has been revised to delete "water solid," thereby requiring the barriers regardless of water level.

Existing Specification 3.3.2.A.(1) refers to a no-flow test of the SIS in Specification 4.2. The intent of that reference was to allow the valves to be stroked for surveillance testing. At one time the SIS no-flow test was in Specification 4.2; however, when the requirements were incorporated under Specification 4.4.F.1, the reference to 4.2 was inadvertently not corrected.

The new proposed specification (3.3.3.B) corrects this error. The new requirements also clarify that power may be restored to the motor-operated valves, and pneumatic/hydraulic valves to operate them for the surveillance test.

Action statement time limits have been added to provide specific guidance to operations to restore an inoperable positive barrier. Action will be required to verify the remaining barrier within one hour, and to restore the second barrier within four hours.

Additionally, the requirement in 3.3.2.A.(4) to place the feedwater pump breaker in the racked out position has been changed to provide for operation of the breaker in the test position. This allows the breaker control circuitry to operate for surveillance testing. In the test position the breaker is not racked-in and does not affect the operation of important components.

This revision added a provision to credit a blind flange as a positive barrier. Although there are no current plans to install a blind flange, the provision is being added as a contingency. The Basis sections of existing Specifications 3.3.2 and 3.3.3, have been revised to reflect the proposed revisions contained in new Specifications 3.3.1 and 3.3.2.

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-11

5. SPECIFICATION 3.3.4 REFUELING WATER STORAGE TANK (RWST) AND SAFETY INJECTION (SI) LINES This section is the existing Specification 3.3.3. The section has been renumbered to 3.3.4, and the title changed to "Refueling Water Storage Tank (RWST) and Safety Injection (SI) Lines." As discussed previously, a clarification has been added to indicate that the boron concentration in the SI lines from the RWST to cold leg injection valves MOV-850 A, B, and C, does not have to be maintained when the safety injection lines are isolated from the RCS for shutdown, as provided by proposed Specification 3.3.3. This revision has also shortened the title.

6. SPECIFICATION 3.3.5 CONTAINMENT SPRAY SYSTEM The proposed change will combine the existing Containment Spray System requirements under Specification 3.3.1.A.2 with Specification 3.3.4 for the Containment Spray Additive System (Hydrazine Additive System).

These will be moved into the newly revised Section 3.3.5.

It was determined that failure modes of the parallel containment spray flow limiting valves, CV-517 and CV-518, would cause an inadequate flow to the spray header in the event of loss of instrument air. Discussion of the system design and corrective actions were described in LER 89-024, "Unit 1 CV-517 and CV-518 Failure Mode on Loss of Instrument Air," submitted to the NRC on October 30, 1989. These valves are closed during the recirculation phase to direct flow through the orifices and to prevent run-out of the charging pumps.

The proposed change will require the containment spray flow limiting valves, CV-517 and CV-518, be maintained in the open position, and be operable such that they can be closed during the recirculation phase. An action statement has been provided to require an inoperable valve to be closed, or for both recirculation pumps to be operable to ensure adequate suction pressure to the charging pumps.

The proposed change will remove the current provisions of Specification 3.3.1.D, which could permit a recirculation pump to be indefinitely removed from service and would require placing containment spray flow limiting valves CV-517 and CV-518 in the closed position. These proposed changes comply with the corrective action commitment of LER 1-89-024 to submit an amendment request with operability requirements and associated action statements for these valves.

-12 The Containment Spray Additive System consists of a hydrazine tank, two hydrazine additive pumps, and associated flow paths. The system removes iodine under post accident conditions. The proposed change incorporates the associated portion of Section 3.3.4 into Section 3.3.5, with standard action statements to permit normal operation with one train of the additive system inoperable for a period not longer than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The proposed change is consistent with the single failure relaxation assumptions provided in the STS action statements for plant operation with one train out-of-service.

The refueling water pumps operate for containment spray and alternate hot leg recirculation. Proposed Specification 3.3.5 will require both of these pumps be operable in MODES 1 through 4.

7. SPECIFICATION 3.3.6 RCS PRESSURE ISOLATION VALVES The proposed change renumbers/renames Section 3.3.5, "Primary Coolant System Pressure Isolation Valves," to Section 3.3.6, "RCS Pressure isolation Valves."

Minor revisions have been made to move the MODE requirement into the APPLICABILITY section, and to refer to the specification in the action statement. Table 3.3.6-1 has been revised to use the new tag numbers for the existing check valves.

8. SPECIFICATION 3.3.7 COMPONENT COOLING WATER (CCW) SYSTEM The proposed change provides Section 3.3.7 for the Component Cooling Water (CCW) system and the saltwater cooling pumps. The amendment reflects a realignment of the CCW pumps which was completed during the Cycle 11 refueling outage. A modification to the 480 volt system connected CCW pump G-15C to the Train B 480 volt system, and now permits either pump G-15B or G-15C to be selected for CCW Train B operation.

The existing specifications require operability of the non-safety related auxiliary saltwater cooling pump, or screen wash pumps to remove one of the two safety related salt water cooling pumps from operation for a 72-hour period. This requirement was added to the existing specifications because the safety related pumps were not considered to be reliable, and some of the connecting piping was not seismically qualified. Since that time, the safety related pumps have been upgraded with improved valves and the piping has been seismically qualified. A review of failure history for the two safety related pumps since 1984 (through July 1991) has shown that one pump has no recorded failures and the other has been required to be removed from operation on three occasions. The proposed specifications delete the requirement to operate the non-safety related back-up pumps prior to removing a salt water pump from operation.

-13 The action statements in proposed Section 3.3.7 allow a 72-hour period during which time one train of CCW may be removed from operation. In addition, provisions have been added for the long term removal from service of one CCW heat exchanger. This is accomplished by failing the CCW outlet valve of the selected heat exchanger in the open position. The failed valve is considered a passive component. The heat exchanger being removed from service is isolated on both the tube and shell sides, and the associated circuit breakers for the isolation valves are opened. Opening the cross-tie valve between the salt water headers allows both saltwater cooling pump trains to supply the operable CCW heat exchanger. Under these conditions the specification allows the CCW heat exchangers to be removed from service for an extended period of time (seven days) to permit removal of bio-fouling material and for maintenance. The seven day period was selected based on the probability of passive component failure being far lower than the probability of failure of active components. A probabilistic risk assessment study of the change from a 72-hour to seven day allowed outage time showed that the increase in risk of core damage is insignificant.

9. SPECIFICATION 3.3.8 RECIRCULATION LOOP OUTSIDE CONTAINMENT EFFECTIVE LEAKAGE The existing specification 3.3.1.A(4) specifies a limit for recirculation loop leakage outside the containment. The proposed revision relocates this section to new Section 3.3.8. The change will allow this specification to apply in MODES 1 through 4. The action statement governing recirculation loop leakage has been changed from requiring Cold Shutdown within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, to requiring Hot Standby in six hours and Cold Shutdown in 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. This was changed to be consistent with the other action statements in the section. For clarity, an editorial change was made to include parenthesis in the formula for determining leakage. The parenthesis help clarify the order that the calculation must be performed, but do not affect the results of the calculation.

10.

SPECIFICATION 3.5.5 CONTAINMENT ISOLATION -

INSTRUMENTATION A discrepancy exists between Section 3.7 and Section 3.5.5 regarding the operability of the sequencers and sequencer subchannels. Section 3.5.5 addresses an inoperable subchannel of a sequencer for the containment isolation function and has an associated 6-hour action statement. In contrast, Section 3.7, "Auxiliary Electrical Supply," addressing two trains of sequencers, permits entry into a 72-hour action statement for an inoperable sequencer. The amendment will change the action statement for the subchannels to conform with the 72-hour time limit for the sequencer. The 72-hour time limit is consistent with the time limit for the Diesel Generators, and was approved in the Safety Evaluation Report issued. with Amendment No. 84, dated November 14, 1984. The 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> action statement was issued by Amendment 58, dated November 6, 1981, which issued TMI related changes.

-14 The containment isolation function is described in UFSAR Section 7.3. Refer to the enclosed logic diagrams of the containment isolation system and the sequencer, drawings 451355 and 5149180-13. Two trains of three containment pressure transmitters each, provide input directly to the containment isolation logic. These containment pressure transmitter trains (along with two trains of three low pressurizer pressure transmitters) are also connected to the X and Y subchannels within each sequencer train. In addition to the direct actuation from the transmitters, containment isolation also can be actuated by the X and Y subchannels within the sequencers.

NUREG 0578, "TMI-2 Lessons Learned Task Force Status Report and Short Term Recommendations," required a diverse means of initiating containment isolation. A connection was made from the X and Y sequencer subchannels, within each train of sequencers, to the containment isolation logic.

This added the capability to initiate containment isolation from low pressurizer pressure. Pressurizer low pressure initiates containment isolation within the sequencer subchannels independently of the containment pressure. Containment isolation therefore, can be actuated by high containment pressure, low pressurizer pressure, or manually.

An automatic Containment Isolation Signal is generated, within each train, when either (1) two out of three containment high pressure transmitters

.directly actuate the logic, or (2) both X and Y sequencer subchannels cause the sequencer for that train to actuate the containment isolation logic. The X and Y subchannels activate from either high containment pressure, or low pressurizer pressure signals. Removal of a sequencer from service does not prevent containment isolation by the respective train; it effectively only removes the pressurizer low pressure input from the train. Operation without one sequencer subchannel for containment isolation, as listed in the current Specification, does not defeat the containment isolation function in the affected train; therefore the direct actuation channel from the containment pressure transmitters remains operational.

11.

Table 4.1.2 Minimum Equipment Check and Sampling Table 4.1.2, "Minimum Equipment Check and Sampling Frequency," has been updated to include a monthly surveillance of the hydrazine tank volume to be consistent with the associated LCO. The existing specification only required some of the surveillances when the reactor is critical.

The mode requirements have been corrected for Items 2, 9, 12, and 13, to require the surveillances in Modes 1 through 4.

-15

12. SPECIFICATION 4.2.1 EMERGENCY CORE COOLING SYSTEM PERIODIC TESTING New requirements have been added to conform with the STS. An inspection of the containment has been incorporated which conforms with the STS requirement to inspect the containment as part of the establishment of containment integrity, and to inspect areas affected by work inside the containment whenever containment integrity is in effect.

The ECCS valve surveillance has been added to comply with the STS requirements. Although the STS requires a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> surveillance of valves which have power removed, this feature has not been incorporated since de energized valves are normally not required for SONGS 1 operation. One exception is that one of the two RHR heat exchanger valves is required to be de-energized in the open position. However, a surveillance is not required because these valves have control room indication and are located inside the containment, limiting personnel access to the valves.

The STS requires a refueling test to verify each automatic ECCS valve actuates to its correct position. This requirement has not been added because it is covered by the existing surveillance requirements. Existing Specification 4.2.1.I.A, "Hot Safety Injection System Test," includes a verification that the required components operate and sequence on an Safety Injection Signal (SIS). Specification 4.4.F.1 requires SISLOP (SIS with a Loss of Power) test during which verification is made that ECCS components function as specified under a loss of power. Verification of the operation of the cold leg recirculation valve has been added to Specification 4.2.

Additional instrument surveillance requirements have been added for recirculation instrumentation.

13.

SPECIFICATION 4.4 EMERGENCY POWER SYSTEM PERIODIC TESTING An additional section (d) was incorporated into 4.4.F.1 to require verification of component actuation during the SISLOP test.

SIGNIFICANT HAZARDS CONSIDERATION ANALYSIS As required by 10 CFR 50.91 (a)(1), this analysis is provided to demonstrate that Proposed Change Number 151 for San Onofre Nuclear Generating Station, Unit 1 (SONGS 1) does not represent a significant hazards consideration. In accordance with the three factor test of 10 CFR 50.92(c), as demonstrated below, implementation of the proposed amendment was analyzed and found not to:

1) involve a significant increase in the probability or consequences for an

.accident previously evaluated; 2) create the possibility of a new or different kind of accident from any accident previously evaluated; or 3) involve a significant reduction in a margin of safety.

-16 Significant Hazards Consideration Analysis

1.

Will operation of the facility in accordance with this proposed change involve a significant increase in the probability or consequences of any accident previously evaluated?

Response: No The Emergency Core Cooling System (ECCS) is designed to protect the core and to mitigate the radiological consequences in the worst design basis LOCA and MSLB. The ECCS also functions for less-severe accident conditions.

The proposed change revises Technical Specification Section 3.3 by organizing the section by ECCS sub-systems and defining train alignment and MODE operability requirements within each subsection. New action statements and section titles follow the format of the STS. The revised specifications are structured to reflect the appropriate train alignment of the ECCS and incorporate flow path descriptions.

The operability requirements are being revised as follows:

The SONGS 1 design has redundant pump trains connected to common flow paths, such as two pumps connected to three common flow paths. The proposed change provides separate operability requirements for the pumps and flow paths.

ECCS components required to be operable in MODES 1, 2, and 3 above 600 psig are separated from those required for MODE 3 below 600 psig and MODE 4.

Westinghouse Standard Technical Specifications (STS) 72-hour action statements for redundant pump trains and flow paths, including the primary injection and recirculation flow paths, are provided. The proposed change also moves the requirements for the Containment Spray and Component Cooling Water Systems from Section 3.3.1 to separate sections, and revises Table 3.3.5-1 with new valve numbers.

Current administrative controls require entry into Specification 3.0.3 whenever containment spray flow limiting valves CV-517 and CV-518 are found to be inoperable, or whenever one component on the hot leg or cold leg recirculation path is found to be inoperable. A plant shutdown is required within one hour to comply with the requirements of Specification 3.0.3. The proposed change removes the need to enter Specification 3.0.3 by providing action statements for systems with redundant trains to allow continued plant operation for up to 72-hours. This is consistent with the assumption of single failure relaxation in the corresponding action statements of the STS, and is consistent with

-17 assumptions of the accident analyses in Chapter 15 of the UFSAR.

The amendment provides for increased availability of cold leg safety injection by requiring the charging pump and associated flow path to the RCS cold legs in MODE 3 (below 600 psig) and MODE 4. It also requires the hot leg and cold leg recirculation paths to be operable through MODE 4. A provision has also been added to require the secondary recirculation path to be operable in the higher modes of operation. Secondary recirculation is a back-up to the RHR system after a Main Steam Line Break inside the containment. Due to the reduced potential for a steam line break at lower pressures, and the limited time the plant is operated between an RCS pressure of 600 psig and MODE 4, secondary recirculation has not been specified for lower modes. Operability of the recirculation system is not currently required by the existing Specifications, and the additional requirements do not increase the consequences of an accident.

The proposed specifications differ from the STS in the Mode 4 requirements for safety injection. The STS requires one train of recirculation and safety injection to be operable in MODE 4; the proposed specifications allow for a single train below MODE 3 and an RCS pressure of 600 psig. This is necessary to comply with the design feature of SONGS 1 that uses the feedwater pumps for safety injection. It would not be appropriate to apply the standard plant requirement to retain the Safety Injection System fully operational until MODE 4 as the SONGS 1 Safety Injection System has a much higher flow capacity than the standard plant design.

The existing specifications, and proposed specifications, require the feedwater/safety injection pumps to be isolated from the RCS below 500 psig to preclude the potential for overpressurization, or boron dilution of the RCS. The proposed specifications allow isolation of the injection system at an RCS pressure of 600 psig to allow sufficient time to isolate the system prior to reaching the 500 psig limit of Specification 3.3.3.

Our analysis of normal shutdown decay heat removal requirements from 102% power after five hours, has shown that the minimum flow available via a single charging pump, including consideration of overpressurization restrictions on cold leg recirculation valve operation, is sufficient to meet decay heat removal requirements.

Since normal shutdowns and shutdowns required by the Technical Specifications are from a power level of 92% and require more than five hours to be less than 600 psig, the consequences of an accident are not increased.

Proposed Specification 3.3.3 has been changed to allow the feedwater pump breaker to be placed in the test position as a positive barrier. The pump is not powered and cannot operate with the breaker in the test position, and therefore, the operation of the barrier is unchanged. The requirement to provide barriers

-18 when "water solid," had been made more conservative to apply regardless of pressurizer level.

The provision to allow stroke testing of the valves has been changed to correct an out-dated specification reference, and extended to the other valves that are required to be tested. Additionally, specific action statement time limits have been provided for restoring an inoperable barrier. A provision has been added to permit a blind flange to serve as a positive barrier, should that become necessary at some future time. These changes do not alter the effectiveness of the existing specification and therefore these changes do not increase the consequences of an accident.

The Component Cooling Water System specifications have been changed to include the operation of the salt water cooling pumps and to provide an extended action statement time limit for the associated heat exchangers (Refer to our submittals of November 1, 1990 and May 2, 1991 for an evaluation of the heat exchanger action statement time limit).

The existing requirement to retain non-safety related salt water cooling capability has been deleted since the existing safety related pumps and piping have been upgraded and proven reliable. The system will continue to provide component cooling as required and therefore the consequences of an accident are not increased.

The change in the action statement time limit for the containment isolation function of the sequencer subchannels from 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, corresponds to the time limit approved for the sequencer in Amendment No. 84. Operation without the subchannel affects the diversity of one portion of the containment isolation train, and does not disable the affected train. Therefore the containment isolation function will remain redundant and the consequences of an accident are not increased.

Surveillance test requirements for the ECCS have been updated as appropriate for the proposed specifications. These changes are additional surveillance requirements and do not increase the probability or consequences of any accident previously evaluated.

The change does not degrade any physical barriers which could alter the consequences analyzed in the UFSAR, and therefore the proposed change do not involve a significant increase in the probability or consequences of any accident previously evaluated.

0II

• II

-19

2.

Will operation of the facility in accordance with this proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change will revise Section 3.3, the ECCS Specifications, consistent with the STS. The proposed change will incorporate current STS guidance into the Technical Specifications by providing a 72-hour action statement for inoperable trains of ECCS. The proposed change also removes an action statement requirement to test redundant components when a component is removed from service. This existing requirement has caused unnecessary entry into Specification 3.0.3. The operability requirements of the redundant trains of the Safety Injection System will require one train of cold leg injection, and hot and cold leg recirculation, via the charging system, to be operable in MODE 4, consistent with the STS.

The amendment provides for increased availability of cold leg safety injection by requiring the charging pump and associated flow path to the RCS cold legs in MODE 3 (below 600 psig) and MODE 4. It also requires the hot leg and cold leg recirculation paths to be operable through MODE 4. A provision has also been added to require the secondary recirculation path to be operable in the higher modes of operation. Secondary recirculation is a back-up to the RHR system after a Main Steam Line Break inside the containment. Due to the reduced potential for a steam line break at lower pressures, and the limited time the plant is operated between an RCS pressure of 600 psig and MODE 4, secondary recirculation has not been specified for lower modes.

Operability of the recirculation system is not currently required by the existing Specifications, and the additional requirements do not create the potential for a new type of accident.

Specification 3.3.3 requires isolation of the safety injection/feedwater pumps at an RCS pressure of 500 psig. The proposed change will allow the isolation to be initiated at 600 psig and completed before reaching 500 psig. The addition of a 100 psi margin for isolation of the safety injection and feedwater pumps will reduce the potential for a mass addition transient in low temperature conditions which may exceed the capability of the Overpressure Mitigation System and, consequently, the Appendix G limits for the reactor vessel.

Therefore, this change allows more time to isolate the system and does not create the possibility of a new, or unanalyzed event.

Low temperature overpressurization protection is covered by existing Specification 3.20, and is not affected by this proposed change.

-20 Proposed Specification 3.3.3 has been changed to allow the feedwater pump breaker to be placed in the test position as a positive barrier. The pump cannot operate with the breaker in the test position, and therefore, the operation of the barrier is unchanged. The existing specification reference to a specific surveillance test has been corrected, since the referenced test was changed by a previous amendment, and corrections have been made to permit the required valves to be stroked for the surveillance test. The requirement for the RCS to be "water solid" for two positive barriers has been deleted to require the barriers regardless of the RCS water level.

Specific action statement time limits have been provided for restoring an inoperable barrier. Additionally, a provision has been added to permit a blind flange to serve as a positive barrier, should that become necessary at some future time. These changes do not alter the effectiveness of the existing specification and therefore these changes do not increase the possibility of a new, or analyzed event.

Consistent with the corrective actions provided in LER 89-024, "Unit 1 CV-517 and CV-518 Failure Mode on Loss of Instrument Air,"

the proposed change will require valves CV-517 and CV-518 to remain open for containment spray by requiring the valves to be operable and capable of remote/manual closure. These valves are closed during the recirculation phase to assure sufficient suction pressure to the charging pumps. However, the action statement permits one valve to be inoperable in the closed position (or open, providing both recirculation pumps are operable) for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Two recirculation pumps will supply adequate charging pump suction and this provision would allow for repair during the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time period.. Therefore, the proposed change does not create the possibility of a new or different type of accident.

The Component Cooling Water System specifications have been changed to include the operation of the salt water cooling pumps and to provide an extended action statement time limit for the associated heat exchanges (Refer to our submittals of November 1, 1990 and May 2, 1991 for an evaluation of the heat exchanger action statement time limit).

The existing requirement to retain non-safety related salt water cooling capability has been deleted since the existing safety related pumps and piping have been upgraded and proven reliable. The system will continue to provide component cooling as required and therefore the change does not create the possibility of a new or different type of accident.

-21 The change in the action statement time limit for the containment isolation function of the sequencer subchannels from 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, corresponds to the time limit approved for the sequencer in Amendment No. 84. Operation without the subchannel affects the diversity of one portion of the containment isolation train, and does not disable the affected train. Therefore, the containment isolation function is not adversely affected, and this change does not create the potential for a new, or different type of accident.

Surveillance test requirements for the ECCS have been updated as appropriate for the proposed specifications. These changes are additional surveillances and do not create the potential for a new, or different type of accident.

The proposed change increases the operability requirements for the ECCS, by providing requirements for ECCS operation not contained in the existing specifications. The increase in ECCS operability does not alter core parameters, or degrade fission product barriers in any manner which would result in a new, or unanalyzed condition.

Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?

Response: No The safety analysis for design basis accidents has concluded that the ECCS will provide sufficient core cooling (for LOCA), and boron injection (for MSLB), to remain within acceptable limits with an assumed worst case single active failure. The proposed change will provide train alignment for ECCS components consistent with the current analysis assumptions and provide for operational flexibility within the analysis. The use of an RCS pressure of 600 psig for isolation of the Safety Injection System, as opposed to the standard plant RCS temperature of 350*F does not reduce the margin of safety since it is within the original plant design and does not degrade the ability to remove core decay heat.

The proposed change will require containment spray flow limiting valves CV-517 and CV-518 to remain open for proper Containment Spray System flow to assure containment peak pressure remains within the safety analysis. The valves also will be required to be operable such that they can be closed for recirculation.

Additional restrictions are placed in the proposed specifications to require operability of the recirculation system. These clarifications and changes to existing requirements were made as a result of recent commitments to upgrade the hot leg recirculation system, and implement the results of the ECCS single failure analysis. Therefore, these changes do not reduce the margin of safety.

-22 The amendment provides for increased availability of cold leg safety injection by requiring the charging pump and associated flow path to the RCS cold legs in MODE 3 (below 600 psig) and MODE 4. It also requires the hot leg and cold leg recirculation paths to be operable through MODE 4. A provision has also been added to require the secondary recirculation path to be operable in the higher modes of operation. Secondary recirculation is a back-up to the RHR system after a Main Steam Line Break inside the containment. Due to the reduced potential for a steam line break at lower pressures, and the limited time the plant is operated between an RCS pressure of 600 psig and MODE 4, secondary recirculation has not been specified for lower modes. The recirculation system operates to maintain core cooling as described in the UFSAR. Operability of the recirculation system is not currently required by the existing Specifications, and the additional requirements do not reduce the margin of safety.

Proposed Specification 3.3.3 has been changed to allow the feedwater pump breaker to be placed in the test position as a positive barrier. The pump cannot operate with the breaker in the test position, and therefore, the operation of the barrier is unchanged. The existing specification reference to a specific surveillance test has been corrected, since the referenced test was changed by a previous amendment. Corrections have been made to permit the required valves to be stroked for surveillance testing. The requirement for the RCS to be "water solid" for two positive barriers has been deleted to require the barriers regardless of the RCS water level.

Specific action statement time limits have been provided for restoring an inoperable barrier.

Additionally, a provision has been added to permit a blind flange to serve as a positive barrier, should that become necessary at some future time. These changes do not alter the effectiveness of the existing specification and therefore these changes do not decrease the margin of safety.

The proposed change provides relief from the provisions of the current Specification requiring 3.0.3 entry, and subsequent plant shutdown. The current Specifications were generally written prior to the issuance of the Westinghouse STS and do not contain action statements for many of the ECCS required components. In most instances the proposed change incorporates the STS action statement time limits into the Specifications. The use of standard action statements will reduce the need to enter 3.0.3, thereby reducing the potential for shutdown transients and does not reduce the margin of safety.

The Component Cooling Water System specifications have been changed to include the operation of the salt water cooling pumps and to provide an extended action statement time limit for the associated heat exchanges (Refer to our submittals of November 1, 1990 and May 2, 1991 for an evaluation of the heat exchanger

-23 action statement time limit).

The existing requirement to retain non-safety related salt water cooling capability has been deleted since the existing safety related pumps and piping have been upgraded and proven reliable. The system will continue to provide component cooling as required and therefore the margin of safety is not reduced by this change.

The change in the action statement time limit for the containment isolation function of the sequencer subchannels from 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, corresponds to the time limit approved for the sequencer in Amendment No. 84. Operation without the subchannel affects the diversity of one portion of the containment isolation train, and does not disable the affected train. The change does not significantly reduce the margin of safety, since it only affects a portion of one train, and the redundant train will remain fully operational. It will permit increased operational flexibility, in accordance with the provisions of Specification 3.7, and reduce the potential for plant transients which could result from implementing the current six hour action statement.

Surveillance test requirements for the ECCS have been updated as appropriate for the proposed specifications. These changes are additional surveillances and do not reduce the margin of safety.

The proposed Technical Specifications for operation of the ECCS are in accordance with the provisions of the STS and the safety analysis contained in the UFSAR Section 15. The proposed change assures the ECCS will be aligned and operated as required by the safety analysis. The proposed revision does not alter the results of the current safety analysis, or decrease the effectiveness of the Technical Specifications in maintaining the analysis limits and assumptions, such as the peak cladding temperature, DNBR, or the peak containment pressure. Therefore, the proposed change will not involve a significant reduction in a margin of safety.

Safety and Significant Hazards Determination Based on the above Safety Analysis, it is concluded that: (1) the proposed change does not constitute a significant hazards consideration as defined by 10 CFR 50.92; (2) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed change; and (3) this action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.

0II

-24 References

1.

"Reply to a Notice of Violation," Mr. Harold B. Ray (SCE) to NRC, dated January 25, 1990.

2.

LER 1-89-018, "Voluntary Entry into Technical Specification 3.0.3 in order to Perform Surveillance of Containment Spray System Pump due to Inadequate TS," dated May 30, 1989.

3.

LER 1-89-024, "Unit 1 CV-517 and CV-518 Failure Mode on Loss of Instrument Air," dated October 30, 1989.

4.

LER 1-89-025, "Unit 1 CV-305 and FCV-1112 Single Failure Deficiency with Hot Leg Recirculation," dated October 12, 1989.

5.

"Amendment Application No. 188," Mr. Harold B. Ray (SCE) to NRC, dated August 31, 1990.

6.

"Amendment Application No. 188, Supplement 1," Mr. H. E. Morgan (SCE) to NRC, dated November 1, 1990.

7. "Amendment Application No. 188, Supplement 1,- Transmittal of PRA,",

Mr. F. R. Nandy (SCE) to NRC, dated May 2, 1991.

8.

"Request for Temporary Waiver of Compliance," R.W. Krieger (SCE), to NRC, dated August 26, 1991.

0II

ATTACHMENT 1 EXISTING TECHNICAL SPECIFICATIONS 0

3.3 SAFETY INJECTION AND CONTAINMENT SPRAY SYSTEMS 3.3.1 OPERATING STATUS APPLicA81LITY:

Applies to the operating status of the Safety Injection and Containment Spray Systems.

OBJECTIVE:

To define those conditions necessary to ensure availability of the Safety Injection and Containment Spray Systems.

SPECIFICATION:

A. The reactor shall not be made or maintained critical unless the following conditions are met. In addition, the reactor coolant system temperature shall not be increased above 200*F unless the containment spray system, the refueling water storage tank and the associated valves and interlocks are operable.

(1) Safety Injection Systems

a. Refueling tank water storage and boron concentration comply with Specification 3.3.3.

b.

ESF Switchover automatic trip channel is OPERABLE with the setpoint less than or equal to 20% and greater than or equal to 18% of RWST level.

c. Two safety injection pumps are OPERABLE.

d. Two feed water pumps are OPERABLE.

e. Two recirculation pumps are OPERABLE, except as indicated in item 0 below.

f. The recirculation heat exchanger is OPERABLE.

g.

Two charging pumps are OPERABLE.

h. Two component cooling water pumps are OPERABLE.

i.

Two saltwater cooling pumps are OPERABLE. The reactor may be maintained critical with one saltwater cooling pump provided the auxiliary saltwater cooling pump or two screen wash pumps are available as backup. Return the inoperable pump to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in HOT STANBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The backup pump(s) shall be demonstrated operable by test within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of declaring the saltwater cooling pump inoperable.

J. A minimum of 5400 pounds of anhydrous trisodium phosphate is stored in the containment sump in racks provided.

SAN ONOFRE - UNIT 1 3.3-1 AMENDMENT NO:

25, 37, 86, 124. 130

(2) Containment Spray System

a. Two rifueling water pumps are OPERABLE.

b.

Two hydruine additive pumps are OPERASLE.

c. Hydrazine tank level and hydrazine Concentraticn compy with Specification 3.3.4.

(3) Valves and interlocks assoctaid.3wth_*ach of the above systems are OPERAILL.

(4) Effective leakage from the recirculation loo outside the containment shall be less than 623 c:/hr as calculated from the foldOwing formula.

Effective Leakage * &1 x L;

• a2 1

• &3 z L3 where.

L1

• pump and valve leakage which drains to auxiliary building sump LZ a valve leakage in auxiliary building or doghouse L3

• valve leakage outside aI

• iodine release factor for leakage in auxiliary building sump az

• iodine release factor for leakage in auxiliary building or doghouse a3

• iodine release factor for leakage outside the auxiliary building or doghouse If effective leakage from the recirculating loop outside the containment exceeds 625 cc/hr. make necessary repairs to limit leakage to 625 cchr.

within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in COLD SHUTOCHN within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

During critical operation or when the reactor coolant system temerature is above 200*f. as appropriate per IteM A above, maintenance shall be allowed on any one of the following items at any one time:

(1) ae mtor-operated valve at a time (MOY 11008 or 11000) In the recirculation loop upstream of the chaging pump suction header for a period of time net longer than 72 consecutive hours.

SAN ONCFRI

• UNIT.1 3.3-2 AMNUCHENT MO:

Z5, 130

(2) One refueling water pump and/or its associated discharge valve at a time, for a period not longer than 72 consecutive hours.

(3) One hydrazine pump and/or its associated discharge valve (SV600 or 601) at a time, for a period of time not longer than 72 consecutive hours.

(4) One charging pump for a period of time not longer than 72 consecutive hours.

(5) One of the two required component cooling water pumos for a period of time not longer than 72 consecutive hours.

(6) One of the two saltwater cooling pumps with the auxiliary saltwater cooling pump or screen wash pumps available as backup for a period of time not longer than 72 consecutive hours. The backup pump(s) shall be demonstrated operable by test within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of declaring the saltwater pump inoperable.

(7) One train of ESF switchover automatic trip for a period of time not to exceed 72 consecutive hours.

C. Prior to initiating maintenance on any of the components, the duplicate (redundant) component shall be tested to demonstrate availability.

D. In the event of a failure of a recirculating pump, plant operation may continue provided operability of the remaining pump and its associated motive and control power are satisfactorily demonstrated on a daily basis, including verification that the containment spray bypass valves (CV517 and 518) are closed.

The requirements of Specification A assure that before the reactor can be made critical, or before the reactor coolant system heatup is initiated, adequate engineered safeguards are OPERABLE. The limit of 625 cc/hr for the recirculation loop leakage ensures that the combined 0-2 hr EAS thyroid dose due to recirculating loop leakage and containment leakage will not exceed the limits of 10 CFR 100. The formula for determining the leakage incorporates consideration of the significance of leakage in different plant areas. The iodine release factor adjusts actual pump or valve leakage to account for the fraction of the iodine in the leakage which would actually be released to the atmosphere. The iodine release factors in the auxiliary building sump, the auxiliary building or doghouse, and outside are 0.0S, 0.5, and 1.0, respectively.

SAN ONOFRE UNIT 1 3.3-3 AMENDMENT NO:

25, 38, 86, 124. 130

When the reactor is critical or the reactor coolant system temperature is above 200*F, maintenance is allowed per Specifications 8 and C providing requirements in Specification C are met which assure OPERABILITY of the redundant component. The specified maintenance times are a maximum,. and maintenance work will proceed with diligence to return the equipment to an operable condition as promptly as possible. OPERABILITY of the specified components shall be based on the results of Specification No. 4.2.

The allowable maintenance periods are based upon the repair of certain specific items. Based on the demonstration that equipment redundant to that removed from service is OPERABLE, it is reasonable to maintain the reactor at power over this short period of time.

In the unlikely event that the need for safety injection should occur:

functioning of one train will protect the core."ea 4 Containment sprays alone, however, will maintain containment pressure under design pressure.'.

• • functioning of one of the two hydrazine additive pumps and associated discharge valve will effect introduction of hydrazine into containment spray water. This provides for absorption of airborne fission products and reduction of the thyroid doses associated with the maximum hypothetical accident to within 10 CFR 100 limits.

dissolution of 5400 pounds of anhydrous trisodium phosphate stored in the sump will ensure that the pH of the water in the sump will be greater than 7 within four (4) hours, so as to prevent chloride stress corrosion cracking of systems and components exposed to the circulating sump water.

In the event of inoperability of a recirculation pump, plant operation may continue since either pump is sufficient and a daily OPERABILITY demonstration of the remaining pump and its associated motive and control power provides assurance that it will be OPERABLE if required.

The switchever from injection to recirculation modes is a two part process, which consists of the automatic termination of the flow from SI/FW pumps including automatic pump trip and automatic closures of MOV's 850 A, S and C followed by manual realignment to recirculation from the containment sump. The automatic trip setpoint is bounded by the minimum water level in the sump to support recirculation for long term post-LOCA cooling and the minimum RWST level to support charging and containment spray during the manual realignment. The setpoint analysis conservatively determined the automatic trip setpoint to be 20% of the RWST level. The automatic trip setpoint is the result of the combination of the worst single active failure considering SIS and SISLOP conditions.

SAN ONOFRE -UNIT 1 3.3-4 AMENDMENT NO:

25, 37, 124, 130

REFRENCES:

(1) Final Engineering Report and Safety Analysis, Paragraph 10.1.

(2) Final Engineering Report and Safety Analysis, Paragraph 5.1.

(3)'"San Onofre Nuclear Generating Station,* report forwarded by letter dated December 29, 1971, from Jack S. Moore to Director, Division of Reactor Licensing, USAEC, subject:

Emergency Core Cooling System Performance, San Onofre Nuclear Generating Station, Unit 1.

(4) USAEC Safety Evaluation of ECCS Performance Analysis for San Onofre Unit 1, forwarded by letter dated March 6, 1974, from Mr. Donald J. Skovholt to Mr. Jack B. Moore.

(5) Supplement No. I to the Final Engineering Report and Safety Analysis, Section 5, Question 3c.

SAN ONOFRE - UNIT 1 3.3-5 AMENDMENT NO:

25, 130

3.3.2 qHUT.MW STATUIS APLICAITLITY:

Applies to piping connections between the feedwater Condensate system and the reactor coolant system.

To preclude injection of feedwater condensate into the reactor coolant system when the reactor is shut dowA and to preclude the potential for overpressurization when water solid.

PCIFICATION:

A. When reactor fuel asseeblies are in the vessel and the reactor coolant pressure is less than 500 psi;. two "positive barriers" shall be provided between the feedwater condensate system and the piping connections to the reactor coolant system.

Additionally, when the reactor coolant system is water solid at less than 500 psig, two positive barriers shall be provided between the safety Injection system and piping connections to the reactor coolant system.

A ;ositive barrier" is defined as follows:

(1) Matnr Oterlted Valves When closed and tagged with supply breakers open, except that power say be restored during no-flow tests of the safety injection system (Specification No. 4.2).

(2) Pneumatie/Hydraulke Caerated Valves When closed and the condition tagged with the respective hydraulic block valve closed except that they say be opened during no-flow tests of the safety inJection system (Specification No. 4.2).

(3)

Manually Oerated Valves When closed and condition tagged.

(4) eadwaat, Pumn (Ovpreissurization Pratction Only)

When shutdown with the breaker in the racked out condition.

3=1:

Under normal conditions, system operational interlocks assure that injpction of feedwater condensation to the reactor by SAN ONCFRI - UNIT 1 3.3*4 AMENC4ENT NO: 25. 102. 120, 110

the safety injection system cannot occur.01 ) These interlocks include:

1. Actuation of the safety injection relay which do.

energizes the condensate and heater drain PuMps and closes the flow path for condensate, thereby preventing injection of feedwater into the coolant system.

2. Interlocks between the condensate isolation valves at the feedwater pump suction and the safety injection header isolation valves at the pump d4taIrge-shich prevent the opening of the one valve unless the other is closed.

Selow 500 psig the Safety Injecties System lay be removed from service.

Below 400 psig the feedwater system say be removed from service.

Curing these low pressure shutdown reactor coolant system conditions, the interlocks may be overridden for maintenance and/or tests of components of these systems.

However, it is still necessary to prevent intrusion of feedwater condensate or safety injection water into the reactor coolant system. Injection of feedwater has the potential to dilute the system and create a potential for-a reactivity excursion.

Injection of either safety injection water or feedwater, especially during water solid operations.

creates the potential for pressurizing above limits established by 10 CFR 50 Appendix G and as reflected in Technical Specification 3.1.3.

The "two positive barriersO required by this specification provide protection of the Reactor Coolant System against boron dilution and overpressurization when in the low pressure and low temperature conditions.

Two positive barriers are provided in each potential path between the Feedwater Condensate System, Safety Injection System and the RC3.

During period of no-flow testing, an exception is provided on tw of the positive barriers to allow the Components involved in the test to perform their test functions while the remining positive barriers (nos. 3 and 4) remai in effect.

Tagged, as used above, means tagged in accordance with current Southern California Edison Company procedures for tagging of equipment which must not be opefated.

(1)

Final Engineering Report and Safety Analysis.

Paragraph 5.1.

SAN ONCFRE - UNIT 1 3.3.7 AMENOMENT MO: 25. 102. 10 118

3.3.3 MINIMUM BORON CONCENTRATION IN THE REFUELING WATER STORAGE TANK _.g AND SAFETY INJECTION (SI) LINES AND MINIMUM RWST WATER VOLUME APPLICABILITY:

MODES 1, 2, 3 and 4; or as described in Specification 3.2.

08JECTIVE:

To ensure immediate availability of borated water from the RWST for safety injection, containment spray or emergency boration.

SPECIFLCATION: a. The RWST shall be OPERABLE with a level of at least plant elevation 50 feet of water having a boron concentration of not less than 3750 ppm and not greater than 4300 ppm.

b. The safety injection (SI) lines from the RWST to MOV 850 A, 8 and C, with the exception of lines common to the feedwater system, shall be OPERABLE with a boron concentration of not less than 1500 ppm and not greater than 4300 ppm.

ACTION:

A. With the refueling water storage tank inoperable, restore the tank to OPERABLE status within I hour or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

.. With one or both SI lines inoperable due to boron concentration of less than 1500 ppm, restore the SI lines to OPERABLE status within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in at least HOT STANDBY within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

The refueling water storage tank serves three purposes; namely:

(1) As a reservoir of borated water for accident mitigation

purposes, (2) As a reservoir of borated water for flooding the refueling cavity during refueling.

(3) As a deluge for fires in containment.

Approximately 220,000 gallons of borated water is required to provide adequate post-accident core cooling and containment spray to maintain calculated post-accident doses below the limits of 10 CFR 100(1). The refueling water storage tank filled to elevation 50 feet represents in excess of 240,000 gallons.

A boron concentration of 3750 ppm in the RWST and 1500 ppm in the SI lines'is required to meet the requirements of postulated steam line break.(2)(4) A maximum boron concentration of 4300 ppm ensures that the post-accident containment sump water is maintained at a pH between 7.0 and 7.5(3).

SAN ONOFRE

• UNIT 1 3.3-8 AMENDMENT NO:

25, 38, 122, 10

The refueling tank capacity of 240,000 gallons is based on refueling volume requirements and includes an allowance for water not useable because of tank discharge line location.

Sustained temperatures below 32*F do not occur at San Onofre.

At 32*F, boric acid is soluble up to approximately 4650 ppm boron. Therefore, no special provisions for temperature control to avoid either freezing or boron precipitation are necessary.

References:

(1) Enclosure 1 "Post-Accident Pressure' eanaTysis, San Onofrt Unit 1V to letter dated January 19, 1977 in Docket No. 50-206.

(2) 'Steam Line Break Accident Reanalysis, San Onofre Nuclear Generating Station, Unit 1, October 1976' submitted by letter dated December 30, 1976 in Docket No. 50-206.

(3) Additional information, San Onofre, Unit I submitted by letter dated March 24, 1977 in Docket No. 50-206.

(4) Reload Safety Evaluation, San Onafrt Nuclear Generating Station, Unit 1, Cycle 10, edited by J. Skaritka, Revision 1, Westinghouse, March 1989 SAN ONOFRE

• UNIT 1 3.3-9 AMENDMENT NO: 25, 38, 122, 130

3.3.4 MINrMUM SOLUTION VOLUME HYORAZINE CONCENTRATTON IN THE HYORA7:NE 7NK APPLICABILITY:

Applies to the inventory of spray additive solution.

OBJECTYE:

To insure availability of containment spray additive solution of required quality.

SPECIFTCATION: When the reactor coolant system temperature is above 200*F, the hydrazine tank shall contain not less than 150 gallons of aqueous solution having a concentration of not less than 21 wt% N)4

4.

The hydrazine tank serves the purpose of acting as a reservoir of aqueous hydrazine solution for post-accident iodine removal.

100 gallons of V, solution are required to reduce airborne iodine concentration in the event of a loss of coolant accident. By adding a 50% margin to this figure to enshire that NPSH to the spray addition pumps is maintained at all times, a total of 150 gallons is required. This amount fulfills requirements for safety injection operations.

SAN ONOFRE

• UNIT 1 3.3-10 AMENOMENT NO:

25, 130

3.3.5 PRIMARY COOLANT SYSTEM PRESSURE ISOLATION VALVES APPLICABILITY: Applies to the operational status of the primary coolant system pressure isolation valves during MODES 1, 2, 3.

OBJECTIVE:

To increase the reliability of primary coolant system pressure isolation valves thereby reducing the potential of an intersystem loss of coolant accident.

SPECIFICATION:

1. The integrity of all pressure isolation valves listed in Table 3.3.5-1 shall be demonstrated by Specification 4.2.2. Valve leakage shall not exceed the amounts indicated in Table 3.3.5-1.

ACTION:

2. If Specification I cannot be met, an orderly shutdown shall be initiated and the reactor shall be in the COLD SHUTDOWN condition within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

SAN ONOFRE - UNIT 1 3.3-11 NRC order 4/20/81 AMENDMENT NO:

130

TABL1 33.5.-1 PRIMARY COOLANT SYSTEM PRESSURE ISOLATION VALVES Maximumo sytem Valve No.

Allowable Leakace Safety Injection Loop A, cold leg 867a 15.0 GPM Loop 8, cold leg 867b

<5.0 GPM Loop C, cold leg 867c 5.0 GPM Footnote:

41.

Leakage rates less than or equal to 1.0 gpm are considered acceptable.

2. Leakage rates greater than 1.0 gpm but less than or equal to 5.0 gpm are considered acceptable if the latest measured rate has not exceeded the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate of 5.0 gpa by 50% or greater.

3. Leakage rates greater than 1.0 gpm but less than or equal to 5.0 gpm are considered unacceptable if the latest measured rate exceeded the rate determined by the previous test by an amount that reduces the margin between measured leakage rate and the maximum permissible rate of 5.0 gpm by 50% or greater.

4. Leakage rates greater than 5.0 gpm are considered unacceptable.

SAN ONOFRE

• UNIT 1 3.3-12 NRC order 4/20/81 AMENDMENT NO:

130

3.5.5 C"MTAINIONT SCLAT~r%

NS7. jot1'Tc Ao 12LLIT*Y:

Applies to instruantation which Ictuates thre contatuen sphert isolation valves, ContAinment snere purge and exiaus*

valves. and containment soners Instruaentation vent a'cder valves.

7 ensure reliability of the Containment Sphere tsolatten Bravisions.

1811ELCAT!CM:

The instrumientation channels shown in Table 3.5.5-1 smali be OPERABLE with their trio setsoints set Consistent wit- :g values shown In the Trip Set~oint column of Table 3.5.5-2.

A. 4ith an Instrusentation Channel trip set:oint less Conservative than the Allowable Values column of Tible 3.5.5-2, declare the channel Inoperable had apply :e aspicatle ACTION requirement of Table 3.5.5-1 until *Re channel is restored to CPEAAILE Status with the trio setpoint adjusted consistent with the Trip Set;oit

%alue.

8. with an instrumentation channel Inoperable, take the ACTION shown in Table 3..5-1.

AILS:

The CPRASILITY of these instrumentation systems ensure that 1) the associated action will be Initiated wAen te parameter menitored by taci channel or combination thereof reaches its setpoint, 2) the specified coincidence logic is maintained. 3) sufficient redundancy is maintained to ;erlit a channel to be out of service for testing or saintenance.

and 4) sufficient system functional capability is available fra diverse paraseters.

The 0PUA8LITY of these systems is required to provide the overall reliability, redundancy, and diversity assumed available in the facility design for the protection and mitigaties of accident and transient conditions.

The integrated operation of each of these systeMs is consistent with the asumptiaos used in the accident analyses.

HITRAcetl>

(1) NAC letter dated July 2, 1980. free 0. G. Ilsenhut to all pressurized water reactor licensees.

SANONCFRE - UNIT 1 3.51 ANOMENT NO:

S1, 13,12

[AKE LL"4 8

l~OIAL 90.

MINIMUMV ICaL (Valves ltei Is Table 3.6.--)

a) usumal.

2 1

2

1. 2.

J.4 11 hi cmlisk 1pressur~lgh Me~als lI1r6is 2IthIS

1. 2. 3 9

c) Seecer Svhamls Zlsquecr Zseuecer Zlsequaacar

1. 2. 3. 4 d) Safety l1jei46ee

1) Comialmeag Vrsir-ihJiri

~

r itals

5. 2. 3 91%

• ZiPrssr~zr resur-Lm I~r21Zgrass Z1itrala

1. 2. 3 turin AnA Exuhmig J CN-9*6 1V-W4. CV-16. cv-e0. CV-116) bi Ceataimit 1.~ 2. 1' 4 10

AC77!CM STATtriN1'S 7he ;rcvis1ORS Of Sgccf ition 3.0.4 are mat applicable.

ACTION I m itA the mumfer of OPIRAULI OhAnneli one loss :UA t ':I,:T P4uamr of

&annels, to in '40T STANOSY within 4 Mau r 3.1 ML SH'UTCM within trio following 30 hour3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />s: Movevoer* ;MS cmanneol Ray 5o tycassed for urn to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for swrVoeflincu testing

-or Specification 4.1.4.

ACTION 9 With the nuader of OPIERASLE MAWneS on# less tIa t.~e rotal uer of Chamnels. orneratlon say proceed until perforuwace of tio nest required O4ANCL FUNC1'ZCNA.

11U? provided tne imooerable c&anel is placed In the tripped condition wib.hiim I hours.

ACTION 10 with less. than the M11InAj O&Annels MPRuhlE operation may Continue provided the containgent ourle and exhaust valves (MV-9 & POV-IO) are maintained closed.

ACION 11 With the nuifter of OP(RAILI Owanels one less thtan the Total Numer of Otannls, restore the incoprable channel to STANOSY vithin the next G hours and in LD S~j4TN wit~in thIIe statusin 3 ihirs.sorb n tlas O

SA NM

-R UNIT? 1 3.-7AJVIN?

NO:

58. 83, 120

4.2 SAFTY NJCTTO ANn rTANMMT SPRAY SYST F

r 4.2.1 SW MT rN.)ECT!CN AmnO

~ AN E Tsq Y~~

P! O TiC TrEST!N PPLICAA!LITY:

Applies to testing of the Safety Injection System and the Containment Spray System.

CB1JECTTVE:

To verify that the Safety Injection System and the Containment Saray System will respond promptly and prpeerly If required.

PEC1FICATION:

1.

S1it

-Tuets A. Hot Safety Injection System Test (1) When the plant is planned to be shutdown from MOC I operation and is plannfld to enter MOCK S operation, a Hot SIS Test shall be performed in MO0E 3 while RCS pressure is above 1500 psi but not more often than once every 9 months. The test shall Include a determination of the force required to open valves MV 851 A and 8 and the margin of available actuation force.

(2) The test will be considered satIsfactory it:

(a) control board indication and visual observations indicate all Components have operated and sequenced oroperly. That Is, the appropriate pumps have started and/or stooped and started. and all valves have completed their travel.

(b) the measured actuator force for both the HV-851 A and 8 valves is equal to or less than 10,000 (3) If the measured actuator force of either MV-851 A or 8 is between 10.000 and 22.000 lb?. the MV-851 A and I valves shall be considered OPERABLE but the future testing Interval shall be accelerated as determined by the following equation:

Upon receipt of satisfactory data from continuing testing and analysis. the NRC staff will consider a request from Southern California Edison Company to change this number to more accurately reflect existing conditions.

SAN ONCFRE - UNIT 1 4.2.1 AMENOMENT NO: 25. 37, 54, 114, 130 jid

12,.000 where:

T a maximus time In days of operation allowed tefers next surveillance test is required T L. time in days of operation since the last surveillance test F

• measured actuator force (4) If the measured actuator force of either MV-451 A :r 8 is greater than 22.000 lbf, test results small be reported to the NRC pursuant to Scecification 6.9.2 along with proposed'corrective actions.

NRC approval shall be obtained prior to returning the unit to service.

I.

Trisodium Phosphate Test (1) A test of the trisodium phosphate additive shall te conducted once every refueling to demonstrate the availability of the system.- The test shall be performed in accordance-with the following procedure:

(a) The three (3) storage racks are visually observed to have maintained their integrity.

(b) The three (3) racks. each with a storage capacity of 1800 pounds of anhydrous trisodium phosphate additive, are visually observed to te full.

(C) Trisodium phosphate from one of the sample storage racks inside containment shall be submerged without agitation, in 250.5 gallons of 150'F to 175'9 distilled water borated to 3900 OO ppm boron.

(2) The test shall be considered satisfactory if the racks have maintained their integrity, the racks are visually observed to be full, and the trisodium phosphate dissolves to the extent that a minimum ;H of 7.0 is reached within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the start of the test.

SAN ONFRt - UNIT 1 4.2-2 AMENCHENT NO:

25, 37, 114, 1

C. Containment Spray System Test (1) Quring reactor shutdown at Intervals not longer than the normal plant refueling intervals, a "no-flow, system test shall be Conducted to demonstrate proper availability of the system. The test shall be performed either by closing a manual valve in the system or electrically disabling the refueling water pumps and initiating the system by tripping the normal actuation instrumentation.

(2) The test will be considered satisfactory if visual observations indicate all Components have operated satisfactorily.

(3) At least once every second refueling outage an air flow test shall be performed to demonstrate the absence of blockage at each containment spray nozzle.

A. Pump Tests (1) In addition to the above test, the safety injection, recirculation, spray additive and refueling water pumps shall be started at Intervals not to exceed one month to verify that they are in satisfactory running order.

(2) Acceptable levels of performance shall be as follows:

(1) The safety injection pumas shall reach and be capable of maintaining 951 of their rated shutoff head within 10 seconds after starting.

(2) The refueling water pumps shall be capable of maintaining 901 of their rated shutoff head.

(3) The recirculation pumps shall be run dry.

Proper starting of the pump is confirmed by observation of the running current on the ameter.

(4) The spray additive pumps shall be capable of maintaining their rated flow at a discharge pressure not less than 901 of their rated discharge pressure.

SA ONOFRE - UNIT 1 4.2-3 AMENOMENT N0: 25. 37, 114, 130

B. Leakage Testing (1) The recirculation loop outside containment (including the Containment Spray System) shall be pressurized at a pressure equal to or greater than the operating pressure under accident conditions at intervals not to exceed the normal plant refueling interval.

Visual inspections for leakage shall be made and if leakage can be detected, measurements of such leakage shall be made. In addition, pumps and valves of the recirculation loop outside containment which are used during normal operation, shall be visually inspectec for leakage at intervals not to exceed once every six months. If leakage can be detected, measurements of such leakage shall be made.

(2) The non-redundant Containment Spray System piping shall be visually inspected at intervals not to exceed the normal plant refueling interval.

Observations made as part of compliance with Paragraph C, above, or Paragraph I.C(2) of Technical Specification 4.2 will be acceptable as visual inspection of portions of non-redundant Containment Spray System piping.

C. RWST Low Level Trips Monthly, perform a CHANNEL TEST and every refueling interval, perform a CHANNEL CALIBRATION, of the SI/Feedwater Pump trip and the MOV 850A, 8508 and 850C automatic closure on low-low Refueling Water Storage Tank level.

The Safety Injection System is a principal plant safeguard. It provides means to insert negative reactivity and limits core damage in the event of a loss of coolant or steam break accident.

e Preoperational performance tests of the components are performed in the manufacturer's shop. An initial system flow test demonstrates proper dynamic functioning of the system.

Thereafter, periodic tests demonstrate that all components are functioning properly. For these tests, flow through the system is generally not required. However, in the case of the "Hot SIS Test," actual conditions of an SI event are simulated. This test is performed to assure that long-term set of the valve seat faces on HV-851 A and 8 has not caused the valves to become inoperable. The test is required to be performed as the plant is shutting down from MODE 1 in order to assure that the valves have not been disturbed (1.e., the long-term set is still in effect) and that full dynamic conditions that would occur during an actual SI event are simulated. When possible the test should be performed prior SAN ONOFRE - UNIT 1 4.2-4 AMENDMENT NO:

25, 37, 114, 124o 130

to stopping the feedwater pumps (this is not a requirement).

This will further assure that the valves will be in the same condition as when required for an actual Safety tnjection event since the discharge pressure of the feedwater pumps acting on the valves will keep them seated even considering any backpressure built up in the downstream St header.

Theequation used to determine future intervals if actuator force is between 10,000 1b, and 22,000 lb. is developed by shortening the interval in direct proportion to the degree to which the force exceeds 10,000 lb,.

Curing the test, all components are verified to have operated and sequenced properly.

The tests required in this specification will demonstrate :nat all components which do not normally and routinely operate will operate properly and in sequence if required. The portion of the Recirculation system outside the containment sphere is effectively an extension of the boundary of the containment.

The measurement of the recirculation loop leakage ensures that the calculated EAB 0-2 hr. thyroid dose does not exceed 10 CFR 100 limits.

The trisodium phosphate stored in storage racks located in the containment is provided to minimize the possibility of stress corrosion cracking of metal components during operation of the ECCS following a LOCA.

The trisodium phosphate provides this*

protection by dissolving in the sump water and causing its final pH to be raised to 7.0 - 7.5.

The requirement to dissolve trisadium phosphate from one of the sample storage racks in distilled water heated and borated, to the extent recirculating post LOCA sump water is projected to be heated and borated, provides assurance that the stored trisodium phosphate will dissolve as required following a LOCA. The sample storage racks are sized to contain 0.5 pounds of trisodium phosphate. Trisodium phosphate stored in the sample storage racks has a surface area to volume ratio of 1.33 whereas the trisodium phosphate stored in the main racks has a surface area to volume ratio of 1.15.

Visual inspection of the non-redundant piping in the Containment Spray System provides additional assurance of the integrity of that system.

Surveillance testing of the RWST low-low level main feedwater/

safety injection pump trips and automatic closure of MOV 850A, 8508 and 850C valves will ensure that these components will be available to complete their safety functions if required.

SAN ONOFRE - UNIT 1 4.2-AMENOMENT NO:

25, 37, 114, 124, 130.

R FF 1C~ E"Z(1) Final Engineering Report and Safety Analysis, Paragraph 5.1.

(2) *San Onofre Nuclear Generating Station', report forwardej by letter dated December 29, 1971 from Jack B. Moore to Director, Division of Reactor Licensing, USAEC, subject:

Emergency Core Cooling System Performance, San Onofre Nuclear Generating Station, Unit 1.

(3) USAEC Safety Evaluation of ECCS Performance Analysis for San Onofre Unit 1, forwarded by letter dated March 6, 1974 from Mr. Donald J. Skovholt to Mr. Jack B. Moore.

(4) Letter, K. P. Baskin, SCE, to 0. M. Crutchfield, NRC, dated October 16, 1981.

SAN ONOFRE

• UNIT 1 4.2-4 AMENOMENT NO:

37, 114, 130.

4.4 EMERGENCY POWER SYSTEM PERIODIC TESTING APPLICABILITY: Applies to testing of the Emergency Power System.

OBJECTIVE:

To verify that the Emergency Power System will respond promptly and properly when required.

SPECIFICATION: A. The required offsite circuits shall be determined OPERABLE at least once per 7 days by verifying correct breaker alignments and power availability.

B. The required diesel generators shall be demonstrated OPERASLE:

1. At least once per 31 days on a STAGGERED TEST BASIS by:

a. Verifying the diesel performs a OG SLOW START' from standby conditions,

b. Verifying a fuel transfer pump can be started and transfers fuel from the storage system to the day

tank,

c. Verifying the diesel generator is synchronized and running at 6,000 kW (+100 kW, -500 kW) for: 60

minutes,

d. Verifying the diesel generator is aligned to provide standby power to the associated emergency buses,

e. Verifying the day tank contains a minimum of 290 gallons of fuel, and

f. Verifying the fuel storage tank contains a minimum of 37,500 gallons of fuel.

2.

At least once per 3 months by verifying that a sample of diesel fuel from the required fuel storage tanks is within the acceptable limits as specified by the supplier when checked for viscosity, water and sediment.

'All diesel starts for testing and surveillance will be slow starts (greater than 24 seconds duration) except for the fast start required by Technical Specification 4.4.G conducted once per 18 months during shutdown and any other fast start required following specific maintenance involving the fast start capability.

SAN ONOFRE - UNIT 1 4.4-1 AMENOMENT NO.

136

AC Distribution

1. The required buses specified in Technical Specifi cation 3.7, Auxiliary Electrical Supply, shall be determined OPERABLE and energized from AC sources other than the diesel generators with tie breakers without automatic SIS/SISLOP tripping circuitry open between redundant buses at least once per 7 days by verifying correct breaker alignment and power availability.

0. The required DC power sources specified in Technical Specification 3.7 shall meet the following:

1. Each OC Bus train shall be determined OPERABLE and energized at least once per 7 days by verifying correct breaker alignment and power availability.

2. Each 125 volt battery bank and charger shall be demonstrated OPERABLE:

a. At least once per 7 days by verifying that:

(1) The parameters in Table 4.4-1 meet the Category A limits, and (2) The total battery terminal voltage is greater than or equal to 129 volts on float charge.

b. At least once per 92 days and within 7 days after a battery discharge with battery terminal voltage below 110 volts, or battery overcharge with battery terminal voltage above 150 volts, by verifying that:

(1)

Ths parameters in Table 4.4-1 meet the Category B limits, (2) There is no visible corrosion at either terminals or connectors, or the connection resistance of these items is less than 150 x 10-6 ohms, and (3) The average electrolyte temperature of ten connected calls is above 61oF for battery banks associated with OC Bus No. 1 and DC Bus No. 2 and above 48*F for the UPS battery bank.

c.

At least once per 18 months by verifying that:

(1) The calls, call plates and battery racks show no visual indication of physical damage or abnormal deterioration, SAN ONOFRE -

UNIT 1 4.4-2 AMENOMENT NO.

136

(2)

The cell-to-cell and terminal connections are clean, tight and coated with anticorrosion material, (3) The resistance of each cell-to-cell and terminal connection is less than or equal to 150 x 10-6 ohms, (4) The battery charger for 125 volt DC Bus No. 1 will supply at least 800 amps DC at 130 volts DC for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, (5) The battery charger for 125 volt OC Bus No. 2 will supply at least 45 amps DC at 130 volts OC for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and (6) The battery charger for the UPS will supply at least 10 amps AC at 480 volts AC for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> as measured at the output of the UPS invertor.

d. At least once per 18 months, during shutdown, by verifying that the battery capacity is adequate to supply and maintain in OPERABLE status all of the actual or simulited emergency loads for the design duty cycle when the battery is subjected to a battery service test.

e. At least once per 60 months, during shutdown, by verifying that the battery capacity is at least 80%, 851 for 8attery, Bank No. 1, of the manu facturer's rating when subjected.to a performance discharge.test. Once per 60 month interval, this performance discharge test may be performed in lieu of the battery service test required by Surveillance Requirement 4.4.0.2.d.

f. Annual performance diischarge tests of battery capacity shall be given to any battery that shows signs of degradation or has reached 85X of the service life expected for the application.

Oegradation is indicated when the battery capac ity drops more than 10X of rated capacity from its average on previous performance tests, or is below 90% of the manufacturer's rating.

E.

The required Safeguards Load Sequencing Systems (SLSS) shall be demonstrated OPERABLE at least once per 31 days on a STAGGERED TEST BASIS, by simulating SISLOP* conditions and verifying that the resulting interval between each load group is within I 105 of its design interval.

F.

The required diesel generators and the Safeguards Load Sequencing Systems (SLSS) shall be demonstrated OPERABLE at least once per 18 months during shutdown by:

SAN ONOFRE -

UNIT 1 4.4-3 AMENOMENT NO. 136

1. Simulating SISLOP*, and:

a. Verifying operation of circuitry which locks out non-critical equipment,

b. Verifying the diesel performs a OG FAST START from standby condition on the auto-start signal, energizes the emergency buses with permanently connected loads and the auto connected emergency loads* through the load sequencer (with the exception of the feedwater, safety injection, charging and refueling water pumps whose respective breakers may be racked-out to the test position) and operates for k 5 minutes while its generator is loaded with the emergency loads,

c. Verifying that on the safety injection actuation signal, all diesel generator trips, except engine overspeed and generator differential, are automatically bypassed.

2. Verifying the generator capability to reject a load of 4,000 kW without tripping. The generator voltage shall not exceed 4,800 volts and the generator speed shall not exceed 500 rpm (nominal speed plus 75% of the difference between nominal speed and the overspeed trip setpoint) during and following the load rejection.

G. Manual Transfer Switches

1. Verify once every 31 days that the fuse block for breaker 8-1181 in MCC-1 for MTS-7 is removed.

2. Verify once every 31 days that MTS-8 is energized from breaker 8-14808 from MCC-4 and the cabinet door is locked, and that breaker 8-1122 from MCC-1 is locked open.

• SISLOP is the signal generated by a sequencer on coincident loss of voltage on its associated 4160 volt bus (Bus iC or 2C) and demand for safety injection.

• • The sum of all loads on the engine shall not exceed 6,000 kW.

SAN ONOFRE - UNIT 1 4.4-4 AMENDMENT NO: 143