ML20094K085
| ML20094K085 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/08/1995 |
| From: | SOUTHERN CALIFORNIA EDISON CO. |
| To: | |
| Shared Package | |
| ML20094K073 | List: |
| References | |
| NUDOCS 9511160157 | |
| Download: ML20094K085 (29) | |
Text
....
3 O
ECCS-Operating 3.5.2 3.5.2 ECCS -Operating LC0 3.5.2 Two ECCS trains shall be OPERABLE.
APPLICABILITY:
MODES 1 and 2, MODE 3 with pressurizer pressure a 400 psia.
ACTIONS 1
CONDITION REQUIRED ACTION COMPLETION TIME j
A.
One or more trains A.1 Restore train (s) to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable.
OPERABLE status.
AND At least 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available.
B.
Required Action and B.1 Be in MODE 3.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.
AND B.2 Reduce pressurizer 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> pressure to j
< 400 psia.
SAN ON0FRE--UNIT 2 3.5-4 Amendment No.
02/28/95 9511160157 951108 PDR ADOCK 05000361 P
o ECCS-0perating B 3.5.2 BASES APPLICABILITY based on full power operation. Although reduced power would (continued) not require the same level of performance, the accident analysis does not provide for reduced cooling requirements in the lower MODES. The HPSI pump performance is based on the small break LOCA, which establishes the pump performance curve and has less dependence on power. The charging pump performance requirements are based on a small break LOCA.
The requirements of MODES 2, and 3 with RCS pressure 2: 400 psia, are bounded by the MODE I analysis.
The ECCS functional requirements of MODE 3, with RCS pressure < 400 psia, and MODE 4 are described in LC0 3.5.3, "ECCS - Shutdown. "
In MODES 5 and 6, unit conditions are such that the probability of an event requiring ECCS injection is extremely low.
Core cooling requirements in MODE 5 are addressed by LC0 3.4.7, "RCS Loops MODE 5, Loops Filled,"
and LC0 3.4.8, "RCS Loops-MODE 5, Loops Not Filled."
MODE 6 core cooling requirements are addressed by LC0 3.9.4,
" Shutdown Cooling (SDC) and Coolant Circulation-High Water Level," and LC0 3.9.5, " Shutdown Cooling (SDC) and Coolant Circulation-Low Water Level."
ACTIONS ad If one or more trains are inoperable and at least 100% of the ECCS flow equivalent to a single OPERABLE ECCS train is available, the inoperable components must be returned to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based on an NRC study (Ref. 4) using a reliability evaluation and is a reasonable amount of time to effect many repairs.
An ECCS train is inoperable if it is not capable of delivering the design flow to the RCS. The individual components are inoperable if they are not capable of performing their design function, or if supporting systems are not available.
The LC0 requires the OPERABILITY of a number of independent subsystems.
Due to the redundancy of trains and the diversity of subsystems, the inoperability of one component (continued)
SAN ON0FRE--UNIT 2 B 3.5-16 Amendment No.
02/28/95
I 6
ECCS -0perating
)
B 3.5.2 BASES ACTIONS M (contineud) in a train does not render the ECCS incapable of performing its function. Neither does the inoperability of two different components, each in a different train, necessarily result in a loss of function for the ECCS. The intent of this Condition is to maintain a combination of OPERABLE equipment such that 100% of the ECCS flow equivalent to 100%
of a single OPERABLE train remains available. This allows increased flexibility in plant operations when components in opposite trains are inoperable.
An event accompanied by a loss of offsite power and the failure of an emergency DG can disable one ECCS train until power is restored. A reliability analysis (Ref. 4) has shown that the impact with one full ECCS train inoperable is sufficiently small to justify continued operation for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Reference 5 describes situations in which one component, such as a shutdown cooling total flow control valve, can disable both ECCS trains. With one or more components inoperable, such that 100% of the equivalent flow to a single OPERABLE ECCS train is not available, the facility is in a condition outside the accident analyses.
Therefore, LC0 3.0.3 must be immediately entered.
B.1 and B.2 If the inoperable train cannot be restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and pressurizer pressure reduced to
< 400 psia within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power in an orderly 1
manner and without challenging unit systems.
SURVEILLANCE SR 3.5.2.1 and 3.5.2.2 REQUIREMENTS SR 3.5.2.1 verification of proper valve position ensures that the flow path from the ECCS pumps to the RCS is t
(continued)
SAN ON0FRE--UNIT 2 B 3.5-17 Amendment No.
02/28/95
4 ECCS-0perating B 3.5.2 BASES SURVEILLANCE SR 3.5.2.1 and 3.5.2.2 (continued)
REQUIREMENTS maintained. Misalignment of these valves could render both ECCS trains inoperable.
Securing these valves in position by removing power or by key locking the control in the correct position ensures that the valves cannot be inadvertently misaligned or change position as the result of an active failure. These valves are of the type described in Reference 5, which can disable the function of both ECCS trains and invalidate the accident analysis.
SR 3.5.2.2 verification of the proper positions of the Containment Emergency Sump isolation valves and ECCS pumps / containment spray pumps miniflow valves ensures that ECCS operability and containment integrity are maintained. Securing these valves in position with power available will provide additional assurance that these valves will operate on a RAS. A 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency is considered reasonable in view of other administrative controls ensuring that a mispositioned valve is an unlikely possibility.
SR 3.5.2.3 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation, This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing.
A valve that receives an actuation signal is allowed to be in a nonaccident position provided the valve automatically repositions within the proper stroke time. This Surveillance does not require any testing or valve manipulation.
Rather, it involves verification that those valves capable of being mispositioned are in the correct position.
The 31 day Frequency is appropriate because the valves are operated under procedural control and an improper valve position would only affect a single train. This Frequency has been shown to be acceptable through operating experience.
(continued)
SAN ON0FRE--UNIT 2 B 3.5-18 Amendment No. 02/28/95 i
I
0 9
ECCS-Operating B 3.5.2 BASES SURVEILLANCE SR 3.5.2.4 REQUIIREMENTS (continued)
With the exception of systems in operation, the ECCS pumps are normally in a standby, nonoperating mode. As such, flow path piping has the potential to develop voids and pockets of entrained gases. Maintaining the piping from the ECCS pumps to the RCS full of water ensures that the system will perform properly., vijecting its full capacity into the RCS upon demand.
This will also prevent water hammer, pump cavitation, and pumping of noncondensible gas (e.g., air, nitrogen, or hydrogen) into the reactor vessel following an SIAS or during SDC.
The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the ECCS piping and the adequacy of the procedural controls governing system operation.
SR 3.5.2.5 Periodic surveillance testing of ECCS pumps to detect gross degradation caused by impeller structural damage or other hydraulic component problems is required by Section XI of the ASME Code.
This type of testing may be accomplished by measuring the pump developed head at only one point of the pump characteristic curve. This verifies both that the measured performance is within an acceptable tolerance of the original pump baseline performance and that the performance at the test flow is greater than or equal to the i
performance assumed in the unit safety analysis.
SRs are specified in the Inservice Testing Program, which encompassesSection XI of the ASME Code.Section XI of the ASME Code provides the activities and Frequencies necessary to satisfy the requirements.
SR 3.5.2.6 Discharge head at design flow is a normal test of charging pump performance required by Section XI of the ASME Code. A
)
quarterly Frequency for such tests is a Code requirement.
Such inservice inspections detect component degradation and incipient failures.
For positive displacement charging pumpsSection XI of the ASME Code allows an alternate testing for design flow only.
(continued)
SAN ON0FRE--UNIT 2 B 3.5-19 Amendment No.
02/28/95
ECCS-Operating B 3.5.2 BASES SURVEILLANCE SR 3.5.2.7. SR 3.5.2.8. and SR 3.5.2.9 REQUIREMENTS (continued)
These SRs demonstrate that each automatic CCCS valve actuates to the required position on an actual or simulated SIAS and on an RAS, that each ECCS pump starts on receipt of an actual or simulated SIAS, and that' the LPSI pumps stop on receipt of an actual or simulated RAS.
The 24 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for unplanned transients if the Surveillances were performed with the reactor at power. The 24 month Frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment. The actuation logic is tested as part of the Engineered Safety Feature Actuation System (ESFAS) testing, and equipment performance is monitored as part of the Inservice Testing Program.
SR 3.5.2.10 Periodic inspection of the containment sump ensures that it is unrestricted and stays in proper operating condition.
The.24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during an outage, on the need to have access to the location.. This Frequency is sufficient to detect abnormal degradation and is confirmed by operating experience.
REFERENCES 1.
10 CFR 50, Appendix A, GDC 35.
2.
3.
UFSAR, Section 6.3.
4.
NRC Memorandum to V. Stello, Jr., from R. L. Baer,
" Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975.
5.
IE Information Notice No. 87-01, January 6, 1987.
SAN ONOFRE--UNIT 2 B 3.5-20 Amendment No.
02/28/95
i
'l l
ATTACHMENT "B" POST PCN-299 (TECHNICAL SPECIFICATION IMPROVEMENT PROGRAM) SPECIFICATIONS UNIT 3 t
.o.
ECCS -Operating 3.5.2 3.5.2 ECCS-Operating l
LC0 3.5.2 Two ECCS trains shall be OPERABLE.
APPLICABILITY:
MODES I and 2, l
MODE 3 with pressurizer. pressure a 400 psia.
l ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME-l-
l A.
One or more trains A.1 Restore train (s) to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable.
OPERABLE. status.
AND j
At least 100% of the ECCS flow equivalent j
to a single OPERABLE ECCS train available.
B.
Required Action and B.1 Be in MODE 3.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.
ANQ B.2 Reduce pressurizer 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> pressure to j
l
< 400 psia.
i i
SAN ON0FRE--UNIT 3 3.5-4 Amendment No. 02/28/95 1
l
o ECCS-Operating B 3.5.2 BASES l
APPLICABILITY based on full power operation. Although reduced power would (continued) not require the same level of performance, the accident analysis does not provide for reduced cooling requirements in the lower MODES.
The HPSI pump performance is based on the small break LOCA, which esteblishes the pump performance curve and has less dependence on power. The charging pump performance requirements are based on a small break LOCA.
The requirements of MODES 2, and 3 with RCS pressure a 400 psia, are bounded by the MODE I analysis.
The ECCS fuw:.tional requirements of MODE 3 with RCS pressure < 400 psia, and MODE 4 are described in LCO 3.5.3, "ECCS - Shutdown. "
In MODES 5 and 6, unit conditions are s.sch that the probability of an event requiring ECCS injection is extremely low. Core cooling requirements in MODE 5 are addressed by LC0 3.4.7, "RCS Loops MODE 5, Loops Filled,"
and LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled."
MODE 6 core cooling requirements are addressed by LC0 3.9.4,
" Shutdown Cooling (SDC) and Coolant Circulation-High Water Level," and LC0 3.9.5, " Shutdown Cooling (SDC) and Coolant Circulation-Low Water Level."
ACTIONS A.1 If one or more trains are inoperable and at least 100% of the ECCS flow equivalent to a single OPERABLE ECCS train is available, the inoperable components must be returned to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is based on an NRC study (Ref. 4) using a reliability evaluation and is a reasonable amount of time to effect many repairs.
An ECCS train is inoperable if it is not capable of delivering the design flow to the RCS. The individual components are inoperable if they are not capable of performing their design function, or if supporting systems are not available.
The LC0 requires the OPERABILITY of a number of independent subsystems. Due to the redundancy of trains and the diversity of subsystems, the inoperability of one component (continued)
SAN ON0FRE--UNIT 3 B 3.5-16 Amendment No.
02/28/95
T ECCS -Operating B 3.5.2 i
l BASES ACTIONS
/L1 (contineud) in a train does not render the ECCS incapable of performing its function. Neither does the inoperability of two different components, each in a different train, necessarily l
result in a loss of function for the ECCS. The intent of this Condition is to maintain a combination of OPERABLE equipment such that 100% of the ECCS flow equivalent to 100%
of a single OPERABLE train remains available.
This allows increased flexibility in plant operations when components in opposite trains are inoperable.
An event accompanied by a loss of offsite power and the failure of an emergency DG can disable one ECCS train until power is restored. A reliability analysis (Ref. 4) has shown that the impact with one full ECCS train inoperable is sufficiently small to justify continued operation for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
i Reference 5 describes situations in which one component, such as a shutdown cooling total flow control valve, can disable both ECCS trains.
With one or more components inoperable, such that 100% of the equivalent flow to a single OPERABLE ECCS train is not available, the facility is in a condition outside the accident analyses.
Therefore, LC0 3.0.3 must be immediately entered.
B.1 and B.2 If the inoperable train cannot be restored to L.iRABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LC0 does not apply.
To achieve this r.tatus, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and pressurizer pressure reduced to
< 400 psia within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power in an orderly manner and without challenging unit systems.
SURVEILLANCE SR 3.5.2.1 and 3.5.2.2 REQUIREMENTS SR 3.5.2.1 verification of proper valve position ensures that the flow path from the ECCS pumps to the RCS is (continued)
SAN ON0FRE--UNIT 3 B 3.5-17 Amendment No. 02/28/95
ECCS-0perating B 3.5.2 I
f BASES I
l l
SURVEILLANCE SR 3.5.2.1 and 3.5.2.2 (continued) l REQUIREMENTS maintained. Misalignment of these valves could render both ECCS trains inoperable. Securing these valves in position by removing power or by key locking the control in the correct position ensures that the valves cannot be inadvertently misaligned or change position as the result of j
an active failure. These valves are of the type described in Reference 5, which can disable the function of both ECCS trains and invalidate the accident analysis.
SR 3.5.2.2 verification of the proper positions of the Containment Emergency Sump isolation valves and ECCS pumps / containment spray pumps miniflow valves ensures.that ECCS operability and containment integrity are maintained.
Securing these valves in position with power available will provide additional assurance that these valves will operate on a RAS. A 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency is considered reasonable in view of other administrative controls ensuring that a mispositioned valve is an unlikely possibility.
SR 3.5.2.3 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation.
This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position j
prior to locking, sealing, or securing.
A valve that receives an actuation signal is allowed to be in a nonaccident position provided the valve automatically repositions within the proper stroke time. This Surveillance does not require any testing or valve manipulation.
Rather, it involves verification that those valves capable of being mispositioned are in the correct position.
The 31 day Frequency is appropriate because the valves are operated under procedural control and an improper valve position would only affect a single train.
This Frequency has been shown to be acceptable through operating experience.
(continued)
SAN ON0FRE--UNIT 3 8 3.5-18 Amendment No.
02/28/95
ECCS-Operating B 3.5.2 l
BASES i
SURVEILLANCE SR 3.5.2.4 REQUIIREMENTS (continued)
With the exception of systems in operation, the ECCS pumps are normally in a standby, nonoperating mode. As such, flow path piping has the potential to develop voids and pockets of entrained gases. Maintaining the piping from the ECCS pumps to the RCS full of water ensures that the system will perform properly, injecting its full capacity into the RCS upon demand. This will also prevent water hammer, pump cavitation, and pumping of noncondensible gas (e.g., air, nitrogen, or hydrogen) into the reactor vessel following an SIAS or during SDC. The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the ECCS piping and the adequacy of the procedural controls governing system operation.
SR 3.5.2.5 Periodic surveillance testing of ECCS pumps to detect gross degradation caused by impeller structural damage or other hydraulic component problems is required by Section XI of the ASME Code.
This type of testing may be accomplished by measuring the pump developed head at only one point of the pump characteristic curve. This verifies both that the measured performance is within an acceptable tolerance of the original pump baseline performance and that the performance at the test flow is greater than or equal to the performance assumed in the unit safety analysis.
SRs are specified in the Inservice Testing Program, which encompassesSection XI of the ASME Code.
Section XI of the ASME Code provides the activities and Frequencies necessary to satisfy the requirements.
SR 3.5.2.6 Discharge head at design flow is a normal test of charging pump performance required by Section XI of the ASME Code. A quarterly frequency for such tests is a Code requirement.
Such inservice inspections detect component degradation and incipient failures.
For positive displacement charging pumpsSection XI of the ASME Code allows an alternate testing for design flow only.
(continued)
SAN ON0FRE--UNIT 3 B 3.5-19 Amendment No. 02/28/95
a i
ECCS-Operating B 3.5.2 BASES i
SURVEILLANCE SR 3.5.2.7. SR 3.5.2.8. and SR 3.5.2.9 REQUIREMENTS (continued)
These SRs demonstrate that each automatic ECCS valve actuates to the required position on an actual or simulated SIAS and on an RAS, that each ECCS pump starts on receipt of an actual or simulated SIAS, and that the LPSI pumps stop on receipt of an actual or simulated RAS. The 24 month Frequency is based on the need to perform these Surveillances under the conditions that apply during a plant outage and the potential for unplanned transients if the Surveillances were performed with the reactor.at power. The 24 month Frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment. The actuation logic is tested as part of the Engineered Safety Feature Actuation System (ESFAS) testing, and equipment performance is monitored as part of the Inservice Testing Program.
SR 3.5.2.10 Periodic inspection of the containment sump ensures that it is unrestricted and stays in proper operating condition.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during an i
outage, on the need to have access to the location.
This Frequency is sufficient to detect abnormal degradation and is confirmed by operating experience.
REFERENCES 1.
10 CFR 50, Appendix A, GDC 35.
2.
3.
UFSAR, Section 6.3.
4.
NRC Memorandum to V. Stello, Jr., from R. L. Baer, "kecommended Interim Revisions to LCOs for ECCS Components," December 1, 1975.
5.
IE Information Notice No. 87-01, January 6, 1987.
SAN ON0FRE--UNIT 3 8 3.5-20 Amendment No. 02/28/95
... g i
l i
I ATTACHMENT "C" PROPOSED SPECIFICATIONS UNIT 2 l
l i
l f
I
e.. -
.o ECCS-Operating 3.5.2
~
3.5.2 ECCS-0perating-LCO 3.5.2 Two ECCS trains shall be.0PERABLE.
i APPLICABILITY:
MODES 1 and 2, l
MODE 3 with pressurizer pressure it 400 psia.
~
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME TE706E?L. g y.m.i,l#
PS13shtf AITLJ15R6t6reissbtFiThlfd Q" days A,m.
smmas 0PERABLEntits ?
C e.We,m
.v. sSw&,sp.%
sA+
- %MQ. - '+ 4.4vner.+M%rs,.rar.N-
- - K eX%
i A
A By One or more ECCS B.1 Restore ECCS train (s) 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> i
trains inopeFstile did to OPERABLE
- status.
i t6IC6hdi_ tion (s)MthMi i
thanic ti ua-as,o_ndianon'AR-~^
a s.ana MD -
4 At least 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available.-
B 8
C.
Required' Action and.
0.1 Be in MODE 3.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> l
associated Completion i
Time 6EC6hditidKTA?"46 AN.Q N
B not" met? "* " ~ "" ~
B C.2 Reduce pressurizer 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> pressure to l
< 400 psia.
SAN ON0FRE--UNIT 2 3.5-4 Amendment No.
a
v s ECCS-Operating 8 3.5.2 BASES APPLICABILITY based on full power operation. Although reduced power would (continued) not require the same level of performance, the accident analysis does not provide for reduced cooling requirements i
in the lower MODES. The HPSI pump performance is based on 4
the small break LOCA, which establishes the pump performance
. curve and has less dependence oli power. The charging pump performance requirements are based on a small break LOCA.
The requirements of MODES 2, and 3 with RCS pressure a 400 psia, are bounded by the MODE 1 analysis.
The ECCS functional requirements of MODE 3, with RCS pressure < 400 psia, and MODE 4 are described in LCO 3.5.3, "ECCS - Shutdown. "
In MODES 5 and 6, unit conditions are such that the i
probability of an event requiring ECCS injection is extremely low. Core cooling requirements in MODE 5 are addressed by LC0 3.4.7, "RCS Loops MODE 5, Loops Fille.1,"
and LC0 3.4.8, "RCS Loops-MODE 5, Loops Not Filled."
I MODE 6 core cooling requirements are addressed by LC0 3.9.4,
" Shutdown Cooling (SDC) and Coolant Circulation-High Water Level," and LC0 3.9.5, " Shutdown Cooling (SDC) and Coolant Circulation-Low Water Level."
ACTIONS A.l'and?B?1 4
i If one er =cre train arc inoperable and at least 100% cf the ECCS ficw equivalent t ; single OPERABLE ECCS train i:
cvailable, the incperable componcat: must be returned to OPERABLE statu within 72 Scurs.
The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Complet4en Time i; b;;cd On an MRC study (Ref.-4) using ; reliability evaluation and i: ; reasonable amcunt Of time to effect many repairs.
An ECCS train is inoperable if it is not capable of delivering the design flow to the RCS.
The individual components are inoperable if they are not capable of 1
performing their design function, or if supporting systems are not available.
The LC0 requires the OPERABILITY of a number of independent subsystems.
Due to the redundancy of trains and the diversity of subsystems, the inoperability of one component (continued)
SAN ON0FRE--UNIT 2 B 3.5-16 Amendment No.
- r ECCS-Operating 8 3.5.2 l
i BASES ACTIONS A.1 shdiBIl (continued) l in a train does not render the ECCS incapable of performing its function. Neither does the inoperability of two different components, each in a different train, necessarily result in a loss of function for the ECCS. The intent of this C=diti= is With%#C6hdit16dTAfhhd!lC6HditisdiBMW to l
1 maintain a combinati6n*6f*0PERABLE"ehnijsinnt~s'UEh*thatF100%
of the ECCS flow equivalent to 100% of a single OPERABLE train remains available. This allows increased flexibility t
in plant operations when components in opposite trains are inoperable.
Each of Condition A'and' Condition B includes a combination l
of OPERABLE equipment'such that at least 100% of the ECCS' I
flow equivalent to a singl,,e OPERA, BL_E E,CCS. train r,em,ains ~
),
s s
Condition 'A 'addresse's the' specific condition' where' the' onif affected ECCS subsystem is a single LPSI subtrain.
The~'~
availability of a least 100% of the'ECCS flow equivalent to a single OPERABLE ECCS train is implicit in the definition
" ^ ^ ' '~ '~
^ ' ~ ^ '
of Condition,A.
^ " ' ' ' ' "
If LCO'3~.5'.2' requi'rements'a're not' met' due' only 'to*the existence of Condition A, then the inoperable LPSI subtrain components must bc returned to OPERABLE status within 7 days!
of discovery of Condition A.
This 7-day Completion Time is' i
based on the findings of the deterministic and probabilistic analysis that are discu Ged in Reference 6.
Seven days is a
' reasonable amount off ime to perform many corrective and ' '
t preventative maintenance items on the affected LPSI ~
subtrain. Reference 6 concluded that the overall risk i
l impact of this Completion Time was,either risk-beneficia,1 or l
, risk-neutral. '
Condition' B addre'sses' other scenarios ~where~' the ' avail ability of at least 100% of the ECCS flow equivalent,to a single' '
OPERABLE ECCS train exists but the full requirements of LCO 3.5.2 are not met.
If Condition B exists, then inoperable' components must be restored such that Condition B does not i
exist within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of discovery. The 72 nour Completion Time is based on an NRC reliability study (Ref. 4)'"and is a reasonable amount of tims'to ef,fect, many repairs.
~
(continued) l SAN ON0FRE--UNIT 2 B 3.5-17 Amendment No.
1
a ECCS-Operating B 3.5.2 BASES ACTIONS A.1 aWd7Bil (continued) l An event accompanied by a loss of offsite power and the failure of an emergency DG can disable one ECCS train until power is restored. A reliability analysis (Ref. 4) has shown that the impact with one full ECCS train inoperable is sufficiently small to justify continued operation for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Reference 5 describes situations in which one component, such as a shutdown cooling total flow control valve, can disable both ECCS trains. With one or more components inoperable such that 100% of the equivalent flow to a single OPERABLE ECCS train is not available, the facility is in a condition outside of the accident analyses. Therefore, Iri sUthfassitsat; ion, LCO 3.0.3 must be immediately entered.~
B B
C.1 and 0.2 If the inoperable train cannot be restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LC0 does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and pressurizer pressure reduced to
< 400 psia within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power in an orderly manner and without challenging unit systems.
SURVEILLANCE SR 3.5.2.1 and 3.5.2.2 REQUIREMENTS l
SR 3.5.2.1 verification of proper valve position ensures that the flow path from the ECCS pumps to the RCS is 1
maintained.
Misalignment of these valves could render both ECCS trains inoperable.
Securing these valves in position by removing power or by key locking the control in the correct position ensures that the valves cannot be inadvertently misaligned or change position as the result of an active failure.
These valves are of the type described in Reference 5, which can disable the function of both ECCS i
trains and invalidate the accident analysis.
verification of the preper positions of the Containment j
Emergency Sump isolation valves and ECCS pumps / containment (continued)
SAN ON0FRE--UNIT 2 B 3.5-18 Amendment No.
e s l
ECCS-Operating l.
B 3.5.2 l
BASES SURVEILLANCE SR 3.5.2.1 and 3.5.2.2 (continued)
REQUIREMENTS spray pumps miniflow valves ensures that ECCS operability and containment integrity are maintained.
Securing these valves in position with power available will provide additional assurance that these valves will operate on a RAS. A 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency is considered reasonable in view of other administrative controls ensuring that a mispositioned valve is an unlikely possibility.
SR 3.5.2.3 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation.
This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position prior to locking, sealing, or securing. A valve that receives an actuation signal is allowed to be in a nonaccident position provided the valve automatically repositions within the proper stroke time.
This Surveillance does not require any testing or valve manipulation.
Rather, it involves verification that those valves capable of being mispositioned are in the correct position.
The 31 day Frequency is appropriate because the valves are operated under procedural control and an improper valve position would only affect a single train.
This Frequency has been shown to be acceptable through operating experience.
SR 3.5.2.4 With the exception of systems in operation, the ECCS pumps are normally in a standby, nonoperating mode. As such, flow path piping has the potential to develop voids and pockets of entrained gases. Maintaining the piping from the ECCS pumps to the RCS full of water ensures that the system will perform properly, injecting its full capacity into the RCS upon demand. This will also prevent water hammer, pump cavitation, and pumping of noncondensible gas (e.g., air, nitrogen, or hydrogen) into the reactor vessel following an (continued)
SAN ON0FRE--UNIT 2 B 3.5-19 Amendment No.
.. 9 s ECCS -Operating l
B 3.5.2 BASES SURVEILLANCE SR 3.5.2.4 (continued)
REQUIIREMENTS The 31 day Frequency takes into SIAS or during SDC.
consideration the gradual nature of gas accumulation in the ECCS piping and the adequacy of the procedural controls governing system operation.
SR 3.5.2.5 Periodic surveillance testing of ECCS pumps to detect gross degradation caused by impeller structural damage or other hydraulic component problems is required by Section XI of the ASME Code.
This type of testing may be accomplished by measuring the pump developed head at only one point of the pump characteristic curve.
This verifies both that the measured performance is within an acceptable tolerance of the original pump baseline performance and that the performance at the test flow is greater than or equal to the performance assumed in the unit safety analysis.
SRs are specified in the Inservice Testing Program, which encompassesSection XI of the ASME Code.
Section XI of the ASME Code provides the activities and Frequencies necessary to satisfy the requirements.
SR 3.5.2.6 Discharge head at design flow is a normal test of charging pump performance required by Section XI of the ASME Code. A quarterly Frequency for such tests is a Code requirement.
Such inservice inspections detect component degradation and incipient failures.
For positive displacement charging pumpsSection XI of the ASME Code allows an alternate testing for design flow only.
SR 3.5.2.7. SR 3.5.2.8. and SR 3.5.2.9 These SRs demonstrate that each automatic ECCS valve actuates to the required position on an actual or simulated SIAS and on an RAS, that each ECCS pump starts on receipt of an actual or simulated SIAS, and that the LPSI pumps stop on receipt of an actual or simulated RAS.
The 24 month Frequency is based on the need to perform these (continued)
SAN ON0FRE--UNIT 2 8 3.5-20 Amendment No.
' s i
ECCS-Operating B 3.5.2 BASES SURVEILLANCE SR 3.5.2.7. SR 3.5.2.8. and SR 3.5.2.9 (continued)
Surveillances under the conditions that apply during a plant outage and the potential for unplanned transients if the Surveillances were performed with the reactor at power. The 24 month Frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment.
The actuation logic is tested
'1 as part of the Engineered Safety Feature Actuation System (ESFAS) testing, and equipment performance is monitored as part of the Inservice Testing Program.
)
SR 3.5.2.10 Periodic inspection of the containment sump ensures that it is unrestricted and stays in proper operating condition.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during an 1
outage, on the need to have access to the location.
This Frequency is sufficient to detect abnormal degradation and is confirmed by operating experience.
REFERENCES 1.
10 CFR 50, Appendix A, GDC 35.
2.
3.
UFSAR, Section 6.3.
4.
NRC Memorandum to V. 5tello, Jr., from R. L. Baer,
" Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975.
5.
IE Information Notice No. 87-01, January 6, 1987.
6h (CE?NPSDi995;E"CEOG? Joint? Applications"_ Report!forltoW
' Pre s s u're j Sa fetyj i nj e'ct i oni Sy s t(mfA0T; Ext en si oni"; May 0
1995; SAN ONOFRE--UNIT 2 B315!20a Amendment No.
8 C
4 a,
ATTACHMENT "D" PROPOSED SPECIFICATIONS UNIT 3 i
j l
1
ECCS -Operating
)
3.5.2 3.5.2 ECCS -Operating LC0 3.5.2 Two ECCS trains shall be OPERABLE.
APPLICABILITY:
MODES 1 and 2, MODE 3 with pressurizer pressure a 400 psia.
ACTIONS I
CONDITION REQUIRED ACTION COMPLETION TIME ATMonsli;LPSIBUbtFhi6 AW"SReit'6FsNsbtpitiiR6 7(dyf"i
"""" _ s.;.F_sb.~h')
"" "~~0PE_RA.B.LE.sstate,m.. m m_ d ""
" " " ~
m
_o 4
A A
Bf One or more ECCS B.1 RestoreECCStrain(s) 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> trains inopeFible dus to OPERABLE" status, t61 Condition (s)fotheh tha. n!Co. ndi,t.a.ni A.ml""
io u.n a
AND At least 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available.
B B
C.
Required Action and C.1 Be in MODE 3.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time 6E C6hditf6h?Ai6t AND B not"mst' B
~ " * " * " " * * " ~
g.2 Reduce pressurizer 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> pressure to
< 400 psia.
SAN ON0FRE--UNIT 3 3.5-4 Amendment No.
s ECCS-0perating B 3.5.2
)
i BASES l
1 i
l APPLICABILITY based on full power operation. Although reduced power would l
(continued) not require the same level of performance, the accident l
analysis does not provide for reduced cooling requirements l
in the lower MODES. The HPSI pump performance is based on j
the small break LOCA, which establishes the pump performance i
curve and has less dependence on power. The charging pump l
performance requirements are based on a small break LOCA.
The requirements of MODES 2, and 3 with RCS pressure I
a 400 psia, are bounded by the MODE I analysis.
l l
The ECCS functional requirements of MODE 3, with RCS l
pressure < 400 psia, and MODE 4 are described in LC0 3.5.3, "ECCS - Shutdown. "
In MODES 5 and 6, unit conditions are such that the probability of an event requiring ECCS injection is l
extremely low.
Core cooling requirements in MODE 5 are addressed by LC0 3.4.7, "RCS Loops MODE 5, Loops Filled,"
l and LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled."
l MODE 6 core cooling requirements are addressed by LC0 3.9.4,
" Shutdown Cooling (SDC) and Coolant Circulation-High Water Level," and LC0 3.9.5, " Shutdown Cooling (SDC) and Coolant Circulation-Low Water Level."
ACTIONS A.1BandtBil' If cnc cr mere train: are incperable and at least 100% cf the ECCS ficw equivalent 10 singic OPERABLE ECCS train is available, the incperable component: must be returned to OPERABLE statu: within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The 72 hcur Ccepletion Time is b;;cd en an NRC study (Ref. 4) using a reliability evaluation and i: a rea:cnab?c := cunt Of time tc effect ::ny repairs.
An ECCS train is inoperable if it is not capable of l
delivering the design flow to the RCS. The individual l
components are inoperable if they are not capable of j
performing their design function, or if supporting systems i
are not available.
The LC0 requires the OPERABILITY of a number of independent subsystems. Due to the redundancy of trains and the diversity of subsystems, the inoperability of one component (continued)
SAN ON0FRE--UNIT 3 8 3.5-16 Amendment No.
l
ECCS-Operating i
B 3.5.2 BASES ACTIONS A.1 indTBil'(continued) l in a train does not render the ECCS incapable of performing its function. Neither does the inoperability of two different components, each in a different train, necessarily result in a loss of function for the ECCS.
The intent of this Ccnditicn is sichMfsC6hditich!AihndiC6ndit~16dTB!is to l
maintain a combinatT6n"'bf'0PERABLE"idGipinsnt*subh"thet*100%
of the ECCS flow equivalent to 100% of a single OPERABLE l
train remains available.
This allows increased flexibility in plant operations when components in opposite trains are inoperable.
J E hch Nf? Cohd i.ti on ?A[andicendi t i oh? B Eihdl ddeif aicombi nati on 6fiOPERABLE?eqeipment?5uchlthattattliist1100%%f;theiECCS~
fl owl eqsival en.ts to?alsi ngl e10PERABLEf,ECCS itFa.i niirema ini.~
gy
~.n
- ~
~
.e~.~..
,m mm.s Cohd i ti onIAYiddFEs ss sit hEiip4Ei fiEFEondi ti dniishifeithdI;6419 affected1ECCSXsubsystentisfaisinglR LPSI#subtraitR 9 T W ~ ^
avsil abi.11 ty!off atl e a s ti100%$ofs the ?ECCSifl ow ?equ Wal entit6 sisiti le50PERABLE{ECCSitrainsissimp~licitEihithe1 definition"
~ ' ' ~ * " ~
~^~ " ~ ~ ~ ~ ~ ~ ^ ~
ofi..co._d_it,i o._nt_A.
If/LC0]3!5?;2[FepuiEsmhntsiaFeinotimetsddey6hlK t6Tths __
bxi stence ? of4 Condi ti on fAnthenf the si noperabl e ;LPSlis' it che onentsfmusti;beiretsrnedito;0PERABLEsstates %fthini73da
-bf!iscoveMoflC6ndttiosiAhsThii?7sdah:Compliti6njTiselis" bas edf;o_n j<t helfi nd i_nggofstheTdetersi st.s ti.c[;andlprobab11 i s t i 6 analysis thattareidiscussedtinfReference16h1Seven?daysyi.s
~
prasonablef amountjofitimelt.olperformfmany4 re subtrain M References 6Sconcisdsdithatithegover;1 H rtik eventative?maintenancesitensironsthetaffected LPSI" a
{mpaptiofdhi @Copi sti.onijTiineja sfejyerMi sMbenefi(l alfby r,i_sk-ne,ut_Falk.
C6ndi ti onl BTidd Fiis ssiothWFI:sEshiFl oiTsheFe ithdN(a fs i n Viilabil;it oflatileasts100%Lofjthed:ECCSifis(squivalentito OPERABLEiECCS!trainlexistlssbetsthhifel.l!PequirementQofJECO l
315 2:areinotimeth(IfdConditionsBiextst@thenyinoperable" b6mpon.ent simu s ti bej fe s toredMUchith~a.t? Cond i ti_ oni Bl:~ doe si not j
exist!Withinl72(hoursLoffdiscovery?jThes72) hour;Completish Timelis1basedfonlinLNRChreliabilitilstudM(RefM4)fandj~isia reasonabjelamosntQ fjtime;}lto# ffectimanyjrepairsf"
^
(continued)
SAN ON0FRE--UNIT 3 B 3.5-17 Amendment No.
,, il s
ECCS-Operating B 3.5.2 l
BASES ACTIONS A.1 anW B!1'(continued) l l
An event accompanied by a loss of offsite power and the l
I failure of an emergency DG can disable one ECCS train until power is restored. A reliability analysis (Ref. 4) has shown that the impact with one full ECCS train inoperable is sufficiently small to justify continued operation for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
l Reference 5 describes situations in which one component, j
such as a shutdown cooling total flow control valve, can disable both ECCS trains. With one or more components inoperable such that 100% of the equivalent flow to a single OPERABLE ECCS train is not available, the facility is in a i
condition outside of the accident analyses. Therefore, Isi Wuch'Miitdatioy, LC0 3.0.3 must be immediately entered."
B B
0.1 and 0.2 If the inoperable train cannot be restored to OPERABLE status within the associated Completion Time, the plant must be brought to a MODE in which the LC0 does not apply.
To achieve this status, the plant must be br ught to at least j
MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and pressurizer pressure reduced to
< 400 psia within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power in an orderly manner and without challenging unit systems.
l l
SURVEILLANCE SR 3.5.2.1 and 3.5.2.2 REQUIREMENTS SR 3.5.2.1 verification of proper valle position ensures that the flow path from the ECCS pumps to the RCS is maintained. Misalignment of these valves could render both l
ECLS trains inoperable. Securing these valves in position by removing power or by key locking the control in the correct position ensures that the valves cannot be inadvertently misaligned or change position as the result of an active failure.
These valves are of the type described in Reference 5, which can disable the function of both ECCS trains and invalidate the accident analysis.
SR 3.5.2.2 verification of the proper positions of the Containment Emergency Sump isolation valves and ECCS pumps / containment (continued)
SAN ON0FRE--UNIT 3 B 3.5-18 Amendment No.
0 s 3
ECCS-0perating B 3.5.2 BASES i
SURVEILLANCE SR 3.5.2.1 and 3.5.2.2 (continued)
REQUIREMENTS spray pumps miniflow valves ensures that ECCS operability and containment integrity are maintained.
Securing these valves in position with power available will provide additional assurance that these valves will operate on a RAS.
A 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency is considered reasonable in view of other administrative controls ensuring that a mispositioned valve is an unlikely possibility.
SR 3.5.2.3 Verifying the correct alignment for manual, power operated, and automatic valves in the ECCS flow paths provides assurance that the proper flow paths will exist for ECCS operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves were verified to be in the correct position i
prior to locking, sealing, or securing. A valve that j
receives an actuation signal is allowed to be in a nonaccident position provided the valve automatically j
repositions within the proper stroke time. This Surveillance does not require any testing or valve manipulation.
Rather, it involves verification that those valves capable of being mispositioned are in the correct position.
The 31 day Frequency is appropriate because the valves are operated under procedural control and an improper valve position would only affect a single train.
This Frequency has been shown to be acceptable through operating experience.
SR 3.5.2,4 With the exception of systems in operation, the ECCS pumps are normally in a standby, nonoperating mode. As such, flow path piping has the potential to develop voids and pockets of entrained gases. Maintaining the piping from the ECCS pumps to the RCS full of water ensures that the system will perform properly, injecting its full capacity into the RCS upon demand.
This will also prevent water hammer, pump cavitation, and pumping of noncondensible gas (e.g., air, nitrogen, or hydrogen) into the reactor vessel following an (continued)
SAN ON0FRE--UNIT 3 8 3.5-19 Amendment No.
ECCS-Operating B 3.5.2 BASES SURVEILLANCE SR'3.5.2,3 (continued)
REQUIIREMENTS SIAS or during SDC. The 31 day Frequency takes into consideration the gradual nature of gas accumulation in the ECCS piping and the adequacy of the procedural controls governing system operation.
SR 3.5.2.5 Periodic surveillance testing of ECCS pumps to detect gross degradation caused by impeller structural damage or other hydraulic component problems is required by Section XI of the ASME Code.
This type of testing may be accomplished by measuring the pump developed head at only one point of the pump characteristic curve.
This verifies both that the measured performance is within an acceptable tolerance of the original pump baseline performance and that the performance at the test flow is greater than or equal to the performance assumed in the unit safety analysis. SRs are specified in the Inservice Testing Program, which encompassesSection XI of the ASME Code.
Section XI of the ASME Code provides the activities and Frequencies necessary to satisfy the requirements, i
i SR 3.5.2.6 i
i Discharge head at design flow is a normal test of charging pump performance required by Section XI of the ASME Code. A quarterly Frequency for such tests is a Code requirement.
Such inservice inspections detect component degradation and incipient failures.
For positive displacement charging pumpsSection XI of the ASME Code allows an alternate testing for design flow only.
SR 3.5.2.7. SR 3.5.2.8. and SR 3.5.2.9 These SRs demonstrate that each automatic ECCS valve i
actuates to the required position on an actual or simulated SIAS and on an RAS, that each ECCS pump starts on receipt of an actual or simulated SIAS, and that the LPSI pumps stop on receipt of an actual or simulated RAS.
The 24 month Frequency is based on the need to perform these (continued)
SAN ON0FRE--UNIT 3 B 3.5-20 Amendment No.
\\
9 1
ECCS-Operating B 3.5.2 BASES SURVEILLANCE SR 3.5.2.7. SR 3.5.2.8. and SR 3.5.2.9 (continued)
REQUIREMENTS Surveillances under the conditions that apply during a plant outage and the potential for unplanned transients if the i
J Surveillances were performed with the reactor at power. The 24 month Frequency is also acceptable based on consideration of the design reliability (and confirming operating experience) of the equipment. The actuation logic is tested as part of the Engineered Safety Feature Actuation System (ESFAS) testing, and equipment performance is monitored as part of the Inservice Testing Program, SR 3.5.2.10 Periodic inspection of the containment sump ensures that it is unrestricted and stays in proper operating condition.
The 24 month Frequency is based on the need to perform this Surveillance under the conditions that apply during an outage, on the need to have access to the location.
This Frequency is sufficient to detect abnormal degradation and is confirmed by operating experience.
REFERENCES 1.
10 CFR 50, Appendix A, GDC 35.
2.
3.
UFSAR, Section 6.3.
4.
NRC Memorandum to V. Stello, Jr., from R. L. Baer, 1
" Recommended Interim Revisions to LCOs for ECCS Components," December 1, 1975.
5.
IE Information Notice No. 87-01, January 6, 1987.
6h if CEf NPSDt995; E"C E0G 7 Doi nt? Appl i cati onM Reports foW Lop i
~PressureJSafegInjecti.ongystemfApKExtyntiong(Hai j
1995g 4
l i
i SAN ON0FRE--UNIT 3 BT325?20_a Amendment No.
l l